Privacy Policy

Halved Limited (“Halved”) is the operator of the Halved platform and website. Where Halved processes personal data as controller, it is the organisation legally responsible for deciding how and why that personal data is used. Where Halved processes student and school staff platform data for a school, the school is controller and Halved is processor, as explained below.

We are Halved Limited (hereafter referred to as “Halved”, “we”, “us”, “our”) and we are committed to protecting personal data. This privacy notice explains how personal data is collected, used, shared, stored and protected when schools, teachers, School Admins, students and website visitors use the Halved platform at https://www.halved.io, contact us, or use our website.

This notice applies to School Admins, teachers, students and website visitors. It should be read alongside the relevant school privacy notice. For students, parents and legal guardians, the school remains the first point of contact for questions about how student data is used in the school setting.

What this notice covers

This notice applies to personal data processed through the Halved platform and website. It does not replace the school’s privacy notice. It also does not apply to third-party websites or services linked from Halved; those organisations are responsible for their own privacy information.

This version is mainly written for adults, including school staff, parents and legal guardians. Halved will also make student-facing privacy information available before or when students first use the platform, in a concise, age-appropriate form for students using the platform.

Who are we?

Controller and processor status. For personal data processed through a school tenant for the purpose of delivering AI-assisted learning support to that school, the school is the controller and Halved acts as processor under a written data processing agreement. This includes student account data, teacher-created assignments, student assignment work, chat history and AI learning profiles. Halved processes that data only on the school documented instructions, except where UK law requires otherwise. Halved is controller for personal data it processes for its own business purposes, including website enquiries, news updates, supplier and customer administration, sales records, security administration and compliance records.

If you have any questions about this privacy notice or our privacy practices, please contact us:

Legal entity: Halved Limited

Email: dataprivacy@halved.io

Registered office address: 4 Comet House, Calleva Park, Aldermaston, Berkshire, RG7 8JA.

If you are a student, parent or legal guardian and your question concerns student data held in the school platform, please contact the school first. Halved will assist the school in responding to validated requests.

How do we use your data?

Personal data we collect and how it is collected

The personal data processed by Halved depends on how you interact with the platform and website. It may include names (for school staff; for students, a unique identifier and, by default, a first name used within chat, with full names held by the school), school email addresses, school, year group, six school-supplied items about a student’s starting point and support (a reading age, whether the student is working at age expectation in English and in mathematics, and the school’s judgements of how the student manages words in a task, instructions and longer pieces of reading), role, account details, hashed passwords, teacher-created assignment allocations, assignment work and submitted content, student-uploaded content, an optional profile photograph the account holder uploads of themselves, display settings a student chooses, such as text size, spacing and font, student-authored free-text notes, chat messages and AI responses, AI-generated learning profile summaries, student-provided answers to fixed-choice questions about how a student prefers to learn and how they approach their work, activity records showing when a student or a member of staff was working in the platform and on which surface, a record of the days on which each student and member of staff signed in and how many times on each day, optional voice audio where voice features are enabled, safeguarding alert content and metadata, support and enquiry details, news-update preferences, technical and security logs, and cookie or usage information.

Personal data is collected directly from schools and teachers when they configure tenants, classes, assignments and accounts; directly from students when they use the platform; directly from you when you contact Halved or sign up to updates; and automatically from the website or platform through necessary logs, session technologies and cookies.

Where personal data is needed to provide the platform, administer an account, respond to an enquiry, keep the service secure or comply with law, failure to provide it may mean that the relevant service or functionality cannot be provided. Where personal data is optional, Halved will make this clear and explain any effect of declining to provide it.

School and teacher accounts. For platform access, we process names, school email addresses, role, school identifier, hashed password and account administration information. We also hold, for each staff account, the days on which it signed in with a count for each day, and a record of when it was active in the platform, both described under Sign-in days and Staff activity below. Where this relates to the school use of the platform, Halved acts as processor for the school. Where Halved uses school contact details for contract administration, service notices, support, billing, security management or legal compliance, Halved acts as controller and relies on contract necessity, legitimate interests and/or legal obligation, as applicable.

Student accounts. Student accounts are created or authorised by the school. Each student is identified on the Halved side by a unique student identifier, which is the primary record. We hold a school email address for authentication and account communications, and by default the student’s first name for use within chat. A student’s full name is held by the school, not by Halved. Schools may instead choose a no-names configuration, in which even the first name is held by the school and Halved holds only the identifier and email. We also process year group, school and subject or assignment allocations. The school additionally supplies six items about the student, each as a fixed choice. Three are measures the school already holds: a reading age, with the date it was taken, and whether the student is working at age expectation in English and in mathematics. The other three are the school’s three judgements of how the student manages particular kinds of task: what happens when they meet the words in a task, how many instructions they can hold at once, and how they respond to a longer piece of writing to read. A Halved Admin enters these from the school’s own records, which include the school’s support plans for students who have one, or the school’s Halved lead enters them in the school intake described below, from which Halved imports them; the school’s SENCO and School Admin can also enter and change them. All six are recorded as the school states them and neither assessed nor inferred by Halved. From them Halved derives a ceiling on the communication register described below and three further settings, which cap how long a reply may be, how many pieces it is delivered in and how many steps it asks of the student at once; each is a ceiling on what Halved asks of the student and never a floor. Each item is chosen from a list Halved sets, none of the questions asks for SEND status, a diagnosis, a condition or a disability label, and there is no free-text field anywhere in this set. The six items are shown to the school’s SENCO and School Admin, and to a Halved Admin, and not to class teachers or to the student. The platform does not capture SEND, accessibility, health or disability flags. The AI learning profile is built from observed learning behaviour, together with this school-supplied information and the fixed-choice answers a student gives about how they prefer to learn, how they approach their work, what they are interested in and whether they find particular kinds of task difficult, and it does not record any diagnosis, neurodevelopmental condition or disability label. The school is responsible for identifying the relevant Article 6 lawful basis; Halved processes student data only on the school documented instructions and applies appropriate confidentiality, access control, minimisation and security safeguards.

The school intake. A school can give Halved its staff, classes and students itself, before any account exists. Once the school’s data processing agreement is signed, Halved creates one account for the school’s Halved lead, which reaches nothing but the intake until Halved has imported it. The lead enters the school’s contacts; its staff, by name, school email address and role; its classes; and its students, each by school student identifier, school email address and year group, with a first name only where the school shares names, the classes the student is in, and, where the school holds them, the reading age and the two age expectation answers described above. There is no field for a surname and no free text about a student. Halved holds what the lead enters as they enter it, does nothing with it until they send it, reviews it, and then creates the accounts from it. The intake is deleted when Halved has imported it, and otherwise 30 days after it was last changed. Where a school’s student email addresses receive no email, each student is given a first password instead of a setup email; it is made when the school’s lead opens it, shown to the lead once to hand out, and not kept by Halved, and the student chooses their own at first sign-in.

Platform usage and AI learning support. When students and teachers use the platform, Halved processes assignment work, chat conversation history, AI responses, lesson context, role-based identifiers, session timestamps and AI-generated learning profile summaries. The AI learning profile is built from the student’s use of the platform and from the student-provided and school-supplied inputs described in this notice, and is used to personalise future learning support sessions, such as by giving shorter explanations or identifying topics that may need reinforcement. Halved also derives a communication register, a coarse language-pitch value that adjusts the vocabulary and sentence complexity used with the student. This is profiling used only to pitch communication. The register is derived from the student’s year group, from the reading age the school supplies and the school’s answer about words in a task, and from how the student responds during use, which adjusts it over time. It is a setting for how Halved talks to a student and not a judgement of the student: it is not itself a record of ability or attainment, it records no special-category data, and it is not used to make decisions producing legal effects concerning a student or similarly significant effects. Halved’s own record of attainment is separate and is described below.

The learning profile is written down, and school staff read it. The profile is not only an input to the tutor. Halved keeps it as a written record about the student, and it is available to authorised school staff. The record holds the topics the student has worked on, apparent strengths, areas of difficulty, the ways of learning that have helped, engagement notes, the student’s own stated learning goals, a per-topic history of what came up and what looked hard, a year group inferred from what the student has said (which is not the year group the school supplies), and the communication register described above.

Three staff-facing routes read it today, and they are named rather than summarised because they do not all reach the same audience. A member of staff asking Halved’s assistant about a student they are linked to receives a short written account. A teacher’s report about a student is composed from it. And a summary prepared for a parents’ evening is composed from it too, which a teacher may read to a parent or carer. Each of these three carries the same four things and no more: the topics worked on, what has been going well, where the student has found things hard, and the approaches that have helped, together with the student’s own words about how confident they felt after a recent task. The engagement notes and Halved’s internal observations about how a student works are withheld from all three and reach no member of staff, a restriction taken on 11 September 2026.

A fourth route, a panel in the teacher dashboard showing the same record, is built and is switched off. It is not in use, and this notice will say so when that changes.

What the record may not contain, and the control that enforces it. The profile records observed learning behaviour and what the student has told Halved. It records no medical diagnosis, no neurodevelopmental condition and no disability label, and it does not hold SEND, EHCP or similar vocabulary. That is not only a statement of intent: every field is passed through an automated check before it is written, any text matching that vocabulary is dropped rather than stored, and each drop is counted so that Halved can see whether the check is doing its job. Halved does not capture SEND, accessibility, health or disability information from the school or the student in the first place.

How the record is described matters as much as who reads it. These are observations about how a student has worked with Halved, not an assessment of the student and not a measure of ability. The wording staff and parents see says so. A student’s record is visible to that student, and a student or their school may ask what it says at any time.

Two of the inputs Halved uses come from the student directly, rather than from observing how they work. A student can optionally tell Halved how confident they feel about the task they are working on, on a simple scale. A student is also asked fixed-choice questions about how they prefer to learn, how they approach their work, what they are interested in, and whether they find particular kinds of task difficult. Every one of these is answered by choosing from options Halved provides, and none of them carries free text. The confidence scale records confidence with a task or skill only, never mood, feelings or wellbeing. The student-answered questions record a preference, a working approach, an interest or a stated difficulty with a kind of task only, and do not ask about health, disability, SEND status, a diagnosis or any other special category of data. Answering is optional in every case, and on the difficulty question each kind of task is answered yes or no, with an item the student has not answered recorded as unanswered rather than as no. The confidence scale is used to personalise the support the student receives, and may be shown to the student’s teachers as a trend over time. Of the answers about how the student prefers to learn and how they approach their work, two change how Halved answers the student: whether they like to know why they are learning something, and what they usually do when they get stuck. The others are kept and do not change what Halved does. A student can also choose whether Halved may explain something a different way when the first way does not help, and can change that choice at any time in their profile; where they say no, Halved does not use their answers to change how it answers them. A student’s answers about how they prefer to learn and how they approach their work are not shown to school staff. A student’s answers about what they are interested in and what they find difficult are for the staff at their school who teach them, so that those staff can use what the student has said about themselves when they plan support; that view is built and is not yet switched on. Where it is, the answers are shown exactly as the student gave them, are identified as the student’s own answers, and are not combined with anything Halved has inferred. The staff who teach a student may also give their own answers to the difficulty question about that student, which are kept separately and shown beside the student’s, never combined with them. Halved does not use the answers about interests or difficulties to change how it answers the student. Halved separately notices what a student appears to be interested in from the conversations they have with it, and that is described under the AI learning profile above; where both exist they are kept apart and labelled, because what a student has said and what Halved has inferred are different kinds of information. Halved does not use identifiable student personal data to train third-party foundation models or for independent product development. Any service-improvement analysis using student-derived data must be carried out only on an anonymised or aggregated basis, unless the school has given documented instructions for the specific processing.

Attainment and progress. Halved records how a student is performing on their work, so that teachers can see progress and so that Halved can pitch its support appropriately.

Three things are recorded. First, the marks a teacher gives a student’s work. Second, whether a student’s answer to a question was correct, where that can be determined by a straightforward check rather than by an opinion. Third, how long a student spends working productively on a task that is stretching them.

These are records of what happened on a piece of work. They are shown to the student’s teachers, and to the student, as a picture of progress over time. Halved does not rank students against one another, does not produce league tables, and does not publish comparisons between students.

Attainment is a record of performance on work. It is not a measure of a student’s ability, and it is not a diagnosis. Halved also holds the six items the school supplies, described under Student accounts above, recorded as the school states them and neither assessed nor inferred by Halved. Halved does not record or infer SEND status, developmental stage, cognitive ability, or any special-category data, and neither an attainment record nor a school-supplied measure is used to do so.

Activity and time spent. Halved holds a record of when a student was working in the platform and on which part of it. This is recorded separately from attainment and is a different kind of record: attainment is about how a student did on a piece of work, while this is about when they were working and for how long.

Each activity record covers one continuous period of activity. It holds a start time and an end time, each held to the minute, which part of the platform the student was on (chat, work completion, lesson content, the lesson list, the homepage, or unknown where that could not be determined), and, where it is known, the session the activity belonged to. It also holds how long the period lasted, stored in seconds. The length is worked out before the start and end times are reduced to the minute, so it stays exact and loses nothing in the rounding: a period of seven minutes and thirty-two seconds is held as exactly that length. What Halved does not hold is the second within the minute at which a student started or stopped working. Some records hold no session and a surface of “unknown”, so they record that a named student was active for a period of time without recording anything about what they were doing. The record holds no message content, no work content, no location and no device identifier.

Because these are clock times, they cover whenever a student chooses to work, including evenings, weekends and school holidays.

Halved uses these records for three things: the total time a student has spent working, how much of that time was spent with Halved’s support as a proportion of the total, and a picture of when in the day a student works. These are shown to the student’s teachers. A student also sees their own activity record, including a version of the when-in-the-day view, so that a student can see what is held about their own working time.

Recording, the teacher measures and the student’s own view of their record are all built. Halved committed that the timer creating activity records would be released together with the student’s own view of them, and not before it. That commitment was met: they were released as a single change, so there is no version of Halved in which a student’s working time is recorded while the student has no way to see it. Recording of a student’s activity begins in a given environment of the platform when that release is deployed there, and where it has not been deployed no activity record exists.

Two limits are built into how the record is made. A student’s record holds students only: staff activity is recorded separately, as described under Staff activity below, and is never counted in any figure about a student. And an interval ends at the last moment a student was seen working, not at the later moment the platform noticed they had stopped, so a student who stops and walks away is recorded as having stopped when they stopped. This means the record can understate how long a student spent working, and cannot overstate it.

Activity records are retained for a maximum of 12 months, and in any event are deleted on contract end plus 90 days, as set out in the Data Retention Policy.

Staff activity. Halved also records when a member of staff was active in the platform, in the same way and to the same precision as a student’s activity: a start time and an end time, each held to the minute, the length of the period in seconds, and which part of the platform they were on. A period ends after five minutes without any typing, scrolling, pointer movement or touch, or when the member of staff moves to another page or leaves the tab, exactly as a student’s does. A staff record does not hold the session or the piece of work the member of staff had open, and holds no message content, no work content, no location and no device identifier. Staff records are held apart from students’ records. Halved uses them for pilot reporting, which is reporting how the platform is being used during a school’s pilot: the total active time and the number of sessions for each member of staff, and when they were last active, where a session ends at a pause of more than five minutes. They are shown to a Halved Admin and not to school staff or students, and Halved uses them to report on use of the platform, not to assess any person’s work. Staff records are retained for a maximum of 12 months from the start of the period, and in any event are deleted on contract end plus 90 days, as set out in the Data Retention Policy.

Sign-in days. Each time a student or a member of staff signs in, Halved adds one to a count held against that person and that day. The record holds the date and the number of sign-ins on it, and nothing else: no time of day, no device, no browser, no network address and no location. The date is the school’s own calendar day where the school has chosen a time zone for Halved, and the calendar day in Coordinated Universal Time where it has not, and the record notes which. Halved uses these records for pilot reporting: how many times each person signed in, on how many different days, and the last day they signed in. They are shown to a Halved Admin and not to school staff or students. Sign-in records are retained for a maximum of 12 months, and in any event are deleted on contract end plus 90 days, as set out in the Data Retention Policy. A student’s sign-in records are deleted with the rest of their data when the school asks for that student’s data to be erased.

Sign-in records and staff activity records are switched on in an environment of the platform by a deliberate setting, and were not switched on in any environment schools use before this notice described them. As with other platform data, Halved processes them as processor for the school.

Handwriting, drawing and photographed work. Some students find it easier to write or draw than to type. Halved offers three ways to do this, and they are handled differently.

Where a student writes by hand as a way of entering text, the handwriting is converted into text so that Halved can read it. The image of the handwriting is used only for that conversion, is held in memory for the length of that single request, and is never stored by Halved or by Azure AI Vision, the Microsoft service in the United Kingdom that performs the conversion. Only the resulting text is kept, and it is screened by Halved’s safety checks before it is stored or shown to anyone.

Where a student draws or marks on a lesson slide as part of their work and sends it to their teacher, the marked-up slide is saved as part of that piece of work, in the same way as any other work a student submits, and is retained with the assignment record. Ink a student submits is checked by Halved’s safety checks, and a concern drawn or handwritten into submitted work reaches the school’s designated safeguarding lead in the same way as one written in typed work. The check does not hold the image back, though: the marked-up slide is shown to the person it was sent to whether or not the check has finished. This is different from handwriting a student uses as a way of typing, where the text Halved reads is checked before it is stored or shown to anyone.

Halved also gives a student a jotter: a blank surface, beside the lesson, that the student writes and draws on to work something out. The jotter holds a student’s handwriting and drawing, and also words the student types onto the page. Typed words are checked by Halved’s safety checks as the student writes them, whenever a save adds words the page did not already hold, and again when the work is sent to the teacher. While the student is working, the ink is held as the strokes they have drawn, with each stroke recording which hand made it. When the student sends the work to their teacher, each page they have worked on is saved as an image of that page and retained with the assignment record. As with a marked-up lesson slide, the page is checked by Halved’s safety checks, and as with a marked-up lesson slide the check does not hold it back, so the teacher may see it before the check has finished. That is when a page is saved and kept. A picture of a page is also made while a student is still working, in the case described next, and that one is not kept.

A student can also write and draw on the pages of work they have uploaded themselves. That ink is saved as they work, as the strokes they have drawn, so that it is still there when they turn the page and come back to it. It stays with the student. There is no way to send it to a teacher, and it is not shown to anyone at the school. No teacher or other member of school staff sees it. Halved is given it only when the student asks Halved about the page they are working on: the page and the drawing on it are then combined into a single picture on the student’s own device and sent with that message. That picture is checked by Halved’s safety screening before Halved reads it, it is used to answer the question the student asked, and it is not stored.

While a student is still working. If a student asks Halved about what is on the page in front of them, Halved sends a picture of that page as it stands at that moment to an AI service in the United Kingdom, so that it can describe what is there. That is not the service that works out the replies to their messages, which is in Sweden Central: the description reaches that service as text, and the picture itself is not sent there. That picture includes the working the student has drawn on the page and has not sent to anyone. It is checked by Halved’s safety checks before anything looks at it, it is used only to produce that description, and it is not stored by Halved or by the service: it is held for the length of that one request and then discarded, so there is nothing left to delete afterwards. If the check finds something of concern in what has been drawn, the picture is not described at all, and the concern goes to the school’s designated safeguarding lead in the same way as a concern in a message. What reaches that record is the fact of the concern and its category. No part of the picture, and nothing read from it, is kept in it.

The text a student writes into a piece of work is screened by Halved’s safety checks twice: while the student is drafting, and again in full when the work is submitted. The check while a student is drafting is not continuous. It runs once enough new writing has built up to be worth checking, so a short addition may not be checked as it is typed. The check at submission covers the whole piece of work and always runs, so anything the first check passed over is caught then. Where that text suggests a student may be at risk, it reaches the school’s designated safeguarding lead by the same route as a message typed in chat.

Where a student photographs work they have done on paper and uploads it, the photograph is stored by Halved as part of that piece of work, is screened, and any text in it is read so that Halved can support the student with it. The photograph remains as the image of that piece of work.

What is not checked while a student is still working. Ink a student has drawn on a lesson slide or in the jotter is saved as they work, and it is not screened while it sits there unsent. It is screened at three points instead: when the student submits the work, when the student asks Halved to read their handwriting as text, and when the student asks Halved about the page in front of them. Words the student types onto a page are different, and are checked sooner. They are screened as text each time a save adds words the page did not already hold, which is a fourth point and the only one that runs while a student is still working; the picture Halved looks at does not read sentences, so typed words need a check of their own. The same applies to a short piece of typing in a piece of work, which may not be checked until the work is submitted, as described above. A student’s unsubmitted working is therefore not under continuous safety screening. This is a deliberate position rather than an oversight: the checks run at the points where the work leaves the student or is read by Halved, and submission is what guarantees the whole of it is screened. Ink a student draws on their own uploaded work reaches the third of those points and not the first two: there is no way to submit it, and it cannot be read back as text there, but when the student asks Halved about the page they are on, the page and the drawing are sent together as one picture and are screened before Halved reads them. Until the student asks, it sits unscreened in the same way as any other unsent working, and nobody sees it but the student.

Teachers’ marks and feedback on a student’s work are authored by school staff and are retained with the assignment record. Where a teacher marks a student’s work by drawing on it, that marked-up image is shown to the student. It is scanned for malware, because every file written to Halved’s storage is, but Halved does not read the result of that scan for a file a member of staff has written, so nothing acts on it and the image reaches the student either way. Halved’s content and safeguarding checks are built around what a student writes, so no safeguarding check runs on staff-authored ink. The school is responsible for its own staff conduct and supervision arrangements, which is what stands in place of a check here.

Student control. A student can delete their own working ink at any time before they send the work to their teacher, on a lesson slide and in the jotter alike. Once work has been sent to a teacher it forms part of the assignment record: it is retained for marking and review and cannot be deleted by the student. This applies to a page of jotter working out in the same way as to a marked-up lesson slide. Ink on a student’s own uploaded work is never submitted to a teacher, so the student can remove it at any time, by erasing it or by deleting the upload, which deletes the ink with it. The exception is an upload that Halved’s safety checks have withheld: a student who deletes one no longer sees it, but the upload is kept for staff review and anything drawn on it is kept with it, not deleted. As things stand no ink can be drawn on a withheld upload, because an upload only opens as pages once it has passed those checks. A student who uploads the same work again makes a new upload, which starts with no ink on it. This is deliberate, so that work cannot be withdrawn after a teacher has been asked to look at it, and so that anything a student has disclosed to a member of staff cannot be removed by the student afterwards. Content flagged by Halved’s safety screening is retained for staff review.

Messages from teachers. Teachers can send messages to their students through Halved, for example to remind a class about a deadline or to pass on a note about a piece of work. Halved processes the content of the message, who sent it, who it was sent to, and when. Messages are visible to the student they are sent to and to the staff who sent them. Messages are held for 7 days and are then deleted automatically.

Messages are written by school staff, not generated by Halved’s AI, and Halved does not use them to build a student’s learning profile.

Profile photographs. A student or a member of school staff may choose to add a photograph to their own account. It is optional: no photograph is set when an account is created, and everything works without one. Only the account holder can add or change their own photograph. A student’s photograph is shown to that student, and to staff at that student’s own school. “School staff” here means the roles the platform actually admits: the class teachers a student is linked to, and the school-wide roles, being the head teacher, the SENCO, the pastoral lead, the designated safeguarding lead and the School Admin. Which of those a school uses is the school’s own configuration. This is the same audience that already sees the student’s name, and the photograph is shown so that a member of staff can be certain which student they are looking at. It is not shown to staff at any other school. No Halved staff surface displays a student’s photograph; what a Halved Admin can reach is set out under Halved’s own staff below and is unchanged by this.

A photograph of a face is personal data and Halved treats it as such. It is not special category data. Halved does not perform facial recognition, does not match one face against another, and does not use a photograph to identify anyone or to infer anything about them. The photograph is a picture on an account and nothing else.

Before a photograph is stored it is checked by Halved’s safety checks, in the same way as an image a student submits with their work. If the check finds something of concern, or cannot complete for any reason, the photograph is refused and is not stored at all. Where a photograph is refused because the check found something of concern, that goes to the school’s designated safeguarding lead in the same way as a concern in a message. What reaches that record is the fact of the concern and its category. No part of the picture is kept in it.

Photographs are held in the United Kingdom and are retained as set out in the Data Retention Policy.

Reading settings. Halved holds the display settings a student chooses, such as text size, spacing and font, and whether replies in chat are shown as light text on a dark background. Each one is optional and is unset until the student chooses it. They are saved with the student’s account, so that they follow the student to another device, and a copy is kept in the browser on the device the student is using, so that they apply straight away. Only the student can set or change them. They are not shown to school staff; a Halved Admin can see them as part of the student’s account record, as set out below. They are not sent to the AI service, they are not used to build the learning profile, and Halved does not use them to infer anything about the student. A display setting is a choice about how text looks and nothing more. It is not a declared need and not a SEND, accessibility, health or disability flag, and Halved does not ask, and does not record, why a student has chosen it. The settings are deleted with the rest of the student’s account when the school asks for that student’s data to be erased.

Who can see a student’s data. The categories described above are visible to the student’s school. In the platform’s own terms that means the class teachers a student is linked to, and, where the school has configured it, the school-wide roles: the head teacher, the SENCO, the pastoral lead, the designated safeguarding lead and the School Admin. Five categories reach fewer people, as the blocks above and this paragraph set out: a student’s answers about how they prefer to learn and how they approach their work are not shown to school staff; a student’s answers about what they are interested in and what they find difficult are for the staff who teach them, once that view is switched on; the six items the school supplies about a student are shown to the school’s SENCO and School Admin rather than to class teachers; a student’s assignments and the work they submit are shown to the teachers who teach them, being the teacher who set the work and the teachers of a class the student is in, and to the head teacher, the SENCO, the pastoral lead and the designated safeguarding lead, and not to the School Admin; and the display settings a student chooses for reading are not shown to school staff. A student’s profile photograph is likewise not an exception; it is shown to school staff, as the profile photographs block above sets out.

A student’s conversations with Halved. Within the school, the class teachers a student is linked to through a class, and the school-wide roles the school has configured, can read the student’s whole conversation history with Halved. The teacher who set a piece of work can read the conversation about that piece of work beside it, while marking it; a teacher linked to a student only by work they have set can read that conversation and not the whole history. In both, a message that Halved’s safety checks flagged, and Halved’s reply to it, are withheld from every member of staff except the designated safeguarding lead, and if Halved cannot confirm which messages were flagged when a conversation is opened, the conversation is not shown at all. Halved records each such read; a record that cannot be written at once is kept and written later. The record is the one of reads by school staff described below.

Halved’s own staff can also read a school’s data, and this and the two paragraphs that follow cover every category in this notice rather than any one of them. A Halved Admin account operates across schools rather than within a single school, and its holder can read, for any school on the platform, a student’s account record and their safeguarding flags including the short excerpt each carries, and, for any student or member of staff, a usage report built from their sign-in and activity records: how many times and on how many days they signed in and the last day they did, and how long and in how many sessions the platform recorded them working, with the last time it did. It can also read, for every school at once, each answer a student has given to a prompt suggesting a break: which prompt appeared, at 30, 45 or 60 minutes, how many minutes the student’s browser had counted, whether the student took a break or carried on, when, and the student’s first name where Halved’s AI service holds one. It cannot open a student’s learning profile summary, their attainment records or the teacher dashboard: the routes that show them to school staff refuse it. Halved’s assistant for staff reaches a named student’s learning profile for such an account only where the student is in the school recorded on the account itself. Nor, in general, can it read work a student has submitted to a teacher. A Halved Admin account is refused the routes that list a student’s assignments and open a submitted piece of work, and the routes that mark work and return a student’s uploaded files and jotter pages are scoped to the member of staff who authored the lesson material or owns the upload. A Halved Admin account therefore reaches a submitted piece of work only on a lesson that account authored itself. It does not reach a student’s conversation history with Halved or the conversation around a safeguarding flag: the routes that show them refuse it. The one conversation it can open is the conversation about a piece of work set on a lesson it authored itself, beside that work while marking it, with a flagged message and Halved’s reply to it withheld as they are from school staff, and that read is recorded. This access exists so that Halved can operate, support and troubleshoot the platform and assist a school with its own requests, and it is limited to the Halved staff holding that role, who are recorded in Halved’s internal admin account register and are subject to the confidentiality obligations in the school’s data processing agreement. It is separate from, and additional to, the school-facing audiences named above.

Most of these reads write an audit record. When a Halved Admin opens the list of safeguarding flags or the flags raised in one conversation, or brings a named student into a staff chat, a row is written recording who read which student’s record, when, and under which reason. On the list of safeguarding flags, a row is written for each student the list shows. Three reads do not write one, and they are named rather than left to be assumed: the account record fetched by student identifier, which is where the stored reference to a profile photograph is returned, the usage report, and the answers to break prompts. Apart from reads of a student’s conversations by school staff, each of which is recorded as described above, Halved does not claim that every access is recorded.

Reads by school staff write the same kind of record. It holds the staff account, the student, the school, the reason, the day, and how many times that day the data was opened, and no content from the student’s records. It has no automatic expiry and is deleted with the rest of the school’s data at the end of the contract, as set out in the Data Retention Policy. It is not deleted when a student’s data is erased. Erasure is requested by school staff, and if it deleted this record, whoever had read a child’s data could remove the record that they did by asking for that child to be erased. Instead the student’s identifier in it is replaced with a reference to the erasure, and the staff account, school, reason, day and count are kept. That reference can be linked back to the student only through Halved’s deletion log, which is described in the Data Retention Policy, and once that log stops naming the student at the end of its retention period it cannot be linked back to them at all.

Separately, and beneath the application, Halved holds break-glass administrative accounts on Microsoft Azure and MongoDB Atlas that reach the stored data directly, including a profile photograph itself rather than the reference to it. Those accounts are recorded in Halved’s internal admin account register, and access through them is logged by Microsoft and by MongoDB rather than by Halved.

News updates. If you sign up to receive our news updates, we collect your name and email address to send them to you. We rely on consent or another lawful basis permitted by the Privacy and Electronic Communications Regulations (PECR) and UK GDPR. You can unsubscribe at any time by using the unsubscribe link in our emails or by emailing dataprivacy@halved.io.

Contact enquiries and support. When you contact us by email, through our website or through a support channel, we collect your name, contact details and the content of your enquiry so that we can respond, administer our services and keep appropriate records. We rely on legitimate interests, contract necessity and/or legal obligation depending on the nature of the enquiry.

Website cookies

For more information about our deployment of and use of cookie information, please see Cookie Policy.

Controller purposes and lawful bases - more detail

The following table gives further detail about Halved controller processing. Student and school staff platform data processed for a school remains subject to the school DPA and the school documented instructions.

When Halved relies on legitimate interests as controller, it will assess whether its interests are overridden by the rights and interests of the relevant individual. You may request information about that assessment by contacting Halved.

Special category data

The platform is not designed to capture special category data and does not collect SEND, accessibility, health or disability flags. The AI-generated learning profile is built from observed learning behaviour, from the fixed-choice answers a student gives, and from the year group and the six items the school supplies, and it does not record any diagnosis, neurodevelopmental condition or disability label. Halved does not solicit special category data. Where Halved asks a question at all, of a student or of a school, the question is fixed-choice and the available answers are set by Halved: students are asked how they prefer to learn, how they approach their work, what they are interested in and whether they find particular kinds of task difficult, and schools are asked for year group, reading age, whether the student is working at age expectation in English and in mathematics, and their judgements of how the student manages words in a task, instructions and longer pieces of reading, which a Halved Admin, or the school’s own Halved lead in the school intake, enters from the school’s own records, including its support plans. None of these questions asks about health, disability, SEND status, a diagnosis or any other special category of data, and none of them offers a free-text answer. Where a student includes sensitive information in a chat message, in uploaded content, in the text of a piece of work, in ink they submit as part of their work, or in handwriting Halved reads, that content is screened through the content-safety pipeline; where a student includes it in a free-text note, that content is not screened but is visible to authorised staff. In either case the school, as controller, is responsible for identifying any applicable Article 9 condition and Data Protection Act 2018 Schedule 1 condition, and Halved processes such content only on the school’s documented instructions.

No sale or advertising use

Halved will not sell student personal data, use student personal data for behavioural advertising, or use student personal data to train third-party foundation models.

Approved applications and AI tools

Halved’s internal approved applications list does not authorise staff or contractors to process student personal data, school-controlled personal data or confidential school materials in general-purpose AI tools, social media tools, Dropbox or other non-platform applications. Those tools must not be used with student data unless separately assessed, approved, covered by appropriate contractual terms and, where required, added to the school DPA and sub-processor register.

Marketing and news updates

Halved will not send marketing or news updates to students through the platform. Adult school contacts and website visitors may receive news updates or service information where permitted by UK GDPR and PECR.

You can opt out of marketing communications at any time by using the unsubscribe link in Halved emails or by contacting dataprivacy@halved.io. This will not affect non-marketing service messages, security notices or communications that Halved is required or permitted to send for contractual, operational or legal reasons.

Halved will not sell personal data or share personal data with third parties for their own marketing purposes.

Processing children’s data

The Halved platform is used by students, including children under the age of 18. Student accounts are created and managed by schools and teachers, not directly by students or parents. Halved processes student personal data only for school educational purposes and on the school’s documented instructions. The following section gives further detail about use of generative AI in an education setting, including child-appropriate safeguards.

Personal data processed in an education setting

This section explains how personal data is processed where Halved is deployed by a school to provide AI-assisted learning support. It is intended to supplement, not replace, the school’s own privacy notice. The school remains the controller for student and school staff platform data and determines the educational purposes and lawful basis for the processing. Halved acts as processor for that school-controlled data under a written data processing agreement, except where Halved separately acts as controller for its own administration, security, legal compliance or business records.

Data subjects who may be affected

The processing may involve students who use the platform, including children aged under 18 and students with SEND or accessibility needs; teachers, tutors, School Admins and designated safeguarding leads who configure or supervise use of the platform; parents or legal guardians where their details or correspondence are provided by the school or included in a support or safeguarding context; and Halved personnel or authorised technical support users whose access is recorded in audit and security logs.

Types of personal data processed

Depending on the school configuration and features enabled, Halved may process identity and account data, such as a unique student identifier, staff names, a student first name where used in chat, school email address, role, school, year group, class and account credentials; educational data, such as teacher-created assignments, lesson context, assignment criteria, submitted work, quiz or task responses, teacher feedback, student-uploaded content and student-authored free-text notes; chat content, including student prompts, AI responses and conversation history; school-supplied information about a student’s starting point and support, being a reading age, whether the student is working at age expectation in English and in mathematics, and the school’s judgements of how the student manages words in a task, instructions and longer pieces of reading, each supplied as a fixed choice and entered from the school’s own records, including its support plans; student-provided answers to fixed-choice questions about how a student prefers to learn and how they approach their work, and an optional task-confidence self-assessment; inferred learning data, including AI-generated learning profile summaries about apparent strengths and areas of difficulty, and about preferred learning approaches where those are inferred rather than stated by the student; optional voice audio and AI-generated audio where speech features are enabled; safeguarding alert content, message excerpts and escalation metadata; activity records of when a student or a member of staff was working in the platform and on which surface, held as interval start and end times, with staff records held apart from students’; records of the days on which each student and member of staff signed in, with a count for each day and no time of day; a student’s answers to prompts in chat suggesting a break, being which prompt appeared, the minutes the student’s browser had counted, whether the student took a break or carried on, and when, held in the United Kingdom with no name stored alongside, with no retention period of their own, since nothing deletes them on a schedule, and deleted when the student’s data is erased; and technical data such as session times, role-based identifiers, security events, audit logs and diagnostic metadata.

How the generative AI works

Halved is a closed-loop educational support tool. It does not browse the internet, does not return public search results and does not use identifiable student personal data to train third-party foundation models. When a student sends a message to the AI, Halved sends the message text, relevant lesson notes, assignment criteria, the text of the page the student is looking at, the immediate conversation context, the student’s first name where the school has Halved hold one, and a limited summary of the student’s learning profile to the Azure OpenAI Service in Microsoft Azure Sweden Central, where the response is generated. Halved does not send the student’s surname or email address. Where a school has chosen for Halved to hold no student name at all, no name is sent. If a student types personal information into a chat message, that information will form part of the message text processed by the AI service. No picture is ever sent to the model that answers a student: where a student asks about the page they are working on, the page is described by a separate call in Azure UK South and only that description is passed into the chat.

Explanation of the AI output

The AI generates natural-language responses by predicting helpful text from the instructions, lesson materials and conversation context supplied to it. The output is not a human decision, is not guaranteed to be error-free, and should not be treated as an official educational assessment, disciplinary decision or safeguarding determination. The AI-generated learning profile is an inferred summary used to adapt future learning support, for example by providing shorter explanations, checking understanding, or revisiting topics that appear difficult. It is not intended to diagnose, label or determine a student’s SEND, disability or health status, and it is not used to make decisions with legal or similarly significant effects about students. Teachers and schools remain responsible for supervising the learning activity, reviewing outputs where appropriate and making educational, pastoral and safeguarding decisions.

Third-party sub-processors used to provide the platform and generative AI

Halved uses the sub-processors listed in the section “Who do we share personal data with?”. For generative AI and related platform delivery, these include Microsoft Azure for hosting, storage, security, logging and infrastructure; MongoDB Atlas for structured platform data; the Azure OpenAI Service for AI learning support responses and for the other AI routes described in the Data Flow and Data Handling Summary; Azure Speech Service where optional speech-to-text or text-to-speech is enabled; Azure Communication Services for transactional and safeguarding escalation emails; Azure Container Instances/Gotenberg for document conversion of teacher-uploaded lesson materials; Azure AI Content Safety and Azure Logic Apps for the safeguarding pipeline. Cloudflare provides DNS, CDN and security for the Halved website (halved.io) only and does not process student or school personal data through the platform. Planned or conditional providers must not process live student data until assessed, contractually covered and activated in accordance with the school DPA and sub-processor notification arrangements.

Lawful basis

Where Halved processes student and school staff platform data for a school, Halved acts as processor and relies on the school’s documented instructions rather than identifying its own Article 6 lawful basis for that school-controlled processing. The school is responsible for identifying and communicating its lawful basis. In many UK state school deployments, the relevant lawful basis is likely to be public task under Article 6(1)(e) UK GDPR, although schools must make their own assessment. Independent schools or other education providers may in some cases rely on legitimate interests, contract necessity, legal obligation or another lawful basis depending on the circumstances.

The platform does not capture SEND, accessibility, health or disability flags, and the fixed-choice questions Halved puts to students and to schools do not ask about any of them. Where safeguarding information or other sensitive information is processed, for example where a student includes such information in a chat message, in uploaded content, or in an unscreened free-text note visible to staff, the school is responsible for identifying an Article 9 condition and any required Data Protection Act 2018 Schedule 1 condition, such as substantial public interest conditions relevant to safeguarding.

Where Halved acts as controller for its own business, security, support, legal or compliance purposes, the lawful bases are set out in the controller purposes and lawful bases section above.

Children’s Code (Age-Appropriate Design Code) safeguards

Halved will apply the following child-privacy safeguards where the platform is used by children, including where those safeguards are adopted as good practice to support the school’s own compliance with the ICO Children’s Code (Age-Appropriate Design Code). In particular, Halved will place students’ best interests at the centre of design and operation; support the school with DPIA information and data flow documentation; provide concise, prominent and age-appropriate privacy information, including point-of-use explanations for AI personalisation/profiling and prompts to ask a teacher or trusted adult if a student is unsure; use high-privacy defaults; collect and use only the personal data needed for the educational purpose; avoid using student data for advertising, sale of data, behavioural profiling, unrelated analytics or independent model training; restrict profiling to explainable learning-support personalisation; avoid nudge techniques that encourage students to weaken privacy settings or share unnecessary personal data; not collect geolocation, biometric data, payment data or device identifiers beyond what is needed for a standard browser session; limit sharing to approved sub-processors; apply role-based access controls, encryption, audit logging and retention limits; and provide routes for students, parents and schools to raise concerns or exercise data protection rights through the school.

School configuration and supervision

Schools should decide which classes, subjects, students and features are appropriate for the deployment, including whether optional voice features are enabled. The safeguarding pipeline is a standard, always-active part of the platform, and each school must provide at least one designated safeguarding lead and a monitored email address to receive safeguarding alerts. Schools should tell students not to include unnecessary personal information in chat messages and should ensure teachers understand that AI outputs are support materials requiring professional oversight, not a substitute for teacher judgement or safeguarding procedures.

Who do we share personal data with?

We share personal data with the following categories of third parties:

• Technology providers and sub-processors: We use the technology providers listed below to operate, host, support and secure the platform. Where student data is processed for a school, these providers act as sub-processors and must be covered by written data processing terms. Planned or conditional providers must not process live student data until they are activated under the school DPA (and the school has been notified where required).

Any contractor access to personal data is permitted only under appropriate Article 28/sub-processor terms, documented access controls, MFA, least privilege and removal of temporary contractor access when no longer required.

Cloudflare fronts the Halved marketing website (halved.io) only and does not sit in front of the student-facing platform (my.halved.io). It therefore processes no student or school personal data and is not a platform sub-processor. This was confirmed in June 2026 by inspecting response headers, which showed Cloudflare serving halved.io but not my.halved.io.

Regulators and authorities. We may share personal data where required by law or where necessary for safeguarding, security, prevention or detection of crime, legal claims, or to protect rights, property or safety. Where Halved is processor, such disclosures will be made in accordance with the DPA, documented instructions or applicable law, and we will inform the school unless legally prohibited.

Halved only allows service providers and sub-processors to handle personal data where Halved is satisfied that they take appropriate measures to protect it and where appropriate contractual obligations are in place. Where Halved acts as processor, sub-processors must be authorised under the school DPA or notified to the school in accordance with that DPA.

Halved may also share relevant personal data with professional advisers, insurers, auditors, banks, law enforcement agencies, courts, public authorities and regulators where necessary for legal, regulatory, accounting, audit, insurance, safeguarding, security or dispute-resolution purposes.

If Halved undergoes a merger, acquisition, asset sale, investment, restructuring or insolvency process, relevant personal data may be shared with the other parties and professional advisers involved. Halved will limit the information shared where possible and will require appropriate confidentiality protections.

Where do we store your data?

Data residency and international transfers. Halved’s application data is stored in UK regions (Microsoft Azure UK South and MongoDB Atlas hosted in Azure UK South), as described in the Data Flow and Data Handling Summary. Halved does not store student personal data outside the UK. AI inference for the chat function is performed by the Azure OpenAI Service from Halved’s production resource in Microsoft Azure Sweden Central, a European Union member state covered by UK adequacy regulations; every other AI route, including the description of a page a student is working on and the reading of uploaded documents, is performed in Azure UK South. Data held by the Azure OpenAI service itself for the Sweden Central resource, for example content retained under Microsoft’s abuse monitoring, is stored in Sweden. This processing takes place on the school’s documented instructions under the Data Processing Agreement. Halved will not move this processing to another region without notifying schools in advance under the Data Processing Agreement, and will not use any region outside the UK or a country covered by UK adequacy regulations without a school’s prior written authorisation.

International transfers - more detail

The only transfer of student personal data outside the UK in the ordinary operation of the platform is the chat inference in Sweden described above. It relies on the UK’s adequacy regulations covering the European Economic Area and needs no further safeguard.

Two limited matters arise from Microsoft’s own operation of its services and are described in the Data Flow and Data Handling Summary: content flagged by Microsoft’s abuse monitoring of the Azure OpenAI Service, which may be reviewed by Microsoft staff (located in the EEA for the Sweden Central resource; Microsoft publishes no location for the UK South resource), and file metadata that Microsoft Defender for Storage may share outside the region in which it scans. Both are covered by the Microsoft Products and Services Data Protection Addendum, including the UK International Data Transfer Addendum where a transfer arises.

Administrative access to Halved’s production systems is exercised by named officers of Halved Limited from the United Arab Emirates under the security controls described in the Data Flow and Data Handling Summary. Because those individuals act for Halved Limited, this is not a transfer of personal data to another organisation.

If Halved ever needs to transfer student personal data outside the UK on any other basis, it will do so only where an adequacy regulation, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses or another lawful transfer mechanism applies, and with the school’s prior authorisation. Halved will not permit access to UK school or student personal data by any non-UK affiliate or operation unless the school has been notified where required and appropriate UK GDPR transfer safeguards and processor or sub-processor arrangements are in place.

How long do we keep your data?

Retention. Student and school staff platform data is retained in accordance with the school contract, the school documented instructions and the Halved Data Retention Policy. Unless a longer period is required by law or the school documented instructions, school-controlled personal data will be deleted or returned within 90 days after termination of the school contract. Safeguarding records must be retained only for the period agreed with the school and aligned with the school safeguarding retention schedule.

Anonymisation. Halved may retain information indefinitely only where it has been anonymised so that individuals are no longer identifiable, taking account of the risk of singling out, linkability, and inference. Pseudonymised data remains personal data and is not treated as anonymised. Halved must not attempt to reidentify anonymised information.

AI profiling and automated decision-making. Halved creates an AI-generated learning profile from a student’s interactions with the platform to personalise learning support. This is profiling/inferred data for data protection purposes, as explained in the section “Personal data processed in an education setting”. The communication register, a coarse language-pitch value derived from the student’s interaction, is included in this profiling. Activity records are a factual record of when a student was working, not an inference about them, but Halved treats the reporting of a student’s working time and time-of-day pattern as profiling for data protection purposes and applies the same limits to it. Neither the learning profile, the communication register nor an activity record is used to make decisions with legal or similarly significant effects about a student, and none of them replaces teacher judgement. Teachers and schools remain responsible for educational decisions.

Keeping personal data secure

Halved uses appropriate technical and organisational measures designed to prevent personal data from being accidentally lost, used, accessed, altered or disclosed unlawfully. These include encryption in transit, encryption at rest, role-based access controls, secrets management, audit logging and controlled administrator access, as described in Halved’s Security Policy.

Access to personal data is limited to people and providers with a genuine need to access it for the purposes described in this notice and, where relevant, under the school DPA. Halved also maintains procedures to deal with suspected personal data breaches.

Administrative and contractor access to production systems is restricted to authorised personnel with a need to know and must use named accounts, MFA, least privilege, password-manager storage, access logging/review and timely removal of temporary contractor access. Administrative access is exercised by named officers of Halved Limited from the United Arab Emirates under these controls; because those individuals act for Halved Limited, this is not a transfer of personal data to another organisation.

Where Halved acts as processor for a school, Halved will notify the school without undue delay after becoming aware of a personal data breach affecting school-controlled personal data. Where Halved acts as controller, Halved will notify affected individuals and/or the ICO where legally required.

What are your rights under data protection law?

Where Halved acts as controller, you may have the rights listed below. Where Halved acts as processor for a school, requests about student or school staff platform data should be made to the school, and Halved will assist the school in responding.

• Request access to your personal data (subject access request): to receive a copy of the data we hold and to check we are processing it lawfully.

• Request correction: to have incomplete or inaccurate data corrected.

• Request erasure: to ask us to delete your personal data where there is no good reason to continue processing it. Note that we may not always be able to comply for specific legal reasons, which we will explain if applicable.

• Object to processing: where we rely on legitimate interest, or where we process your data for direct marketing.

• Request restriction of processing: to ask us to suspend processing in certain circumstances.

• Request data portability: to receive your data in a structured, machine-readable format where applicable.

• Withdraw consent: where we rely on consent. This will not affect the lawfulness of any processing before withdrawal.

You also have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects, where applicable. Halved does not use the platform to make such decisions about students.

You also have the right to lodge a complaint. For more information, please see the section ‘How to complain’ below.

Please be aware that these rights are not absolute and will not be available in all circumstances.

To exercise a right where Halved is controller, please email dataprivacy@halved.io and provide enough information to identify yourself, the right you want to exercise and the personal data to which your request relates. Halved may request additional information if reasonably needed to verify your identity.

Halved will respond to valid rights requests without undue delay and normally within one month, subject to any extension permitted by UK GDPR for complex requests. Where Halved is processor for a school, Halved will assist the school in responding to validated requests.

How to complain

You have the right to make a complaint to us if you are unhappy about how we handle your personal data. You can contact us at dataprivacy@halved.io. We will acknowledge your complaint within 30 days of receiving it and, without undue delay, will take appropriate steps to investigate, keep you informed and tell you the outcome. Full details of how we handle data protection complaints are set out in our Data Protection Complaints Process. You do not need a form or a web page to complain: an email to dataprivacy@halved.io is enough. We will send you that process, or a Data Protection Complaint Form if you would prefer to use one, on request from the same address.

You also have the right to complain to the Information Commissioner’s Office, the UK supervisory authority for data protection. The ICO can be contacted through https://www.ico.org.uk or by telephone on 0303 123 1113.

Do we review this policy?

We review this privacy notice at least once a year, and sooner when our practices change or when required by law. The next scheduled review is June 2027. We will notify schools of material changes affecting school-controlled personal data in accordance with the school DPA. When Halved makes significant changes, it will take appropriate steps to inform schools and, where relevant, website users, for example by notifying school contacts or publishing a notice on the Halved website.

Do you need extra help?

If you would like this notice in another format, such as large print, audio, accessible HTML or another language, please contact dataprivacy@halved.io.