Privacy policy

Introduction

This privacy policy sets out how Foramind Technologies Limited uses and protects your personal data.

Important information and who we are

This privacy policy gives you information about how Foramind Technologies Limited collects and uses your personal data through your use of this website and our AI-powered platform, including any data you may provide when you sign up to our newsletter, input queries or prompts into our services, or purchase our services.

Our website is intended for adults. Children and young people under 18 may use our platform only through an account set up and managed by their school, college, tutor or other organisation under a subscription agreement with us. In that case the school, tutor or organisation is the controller of the pupil's personal data and we process it on its behalf as its processor (see "Controller" below). We do not allow children under 18 to create individual accounts, and if we learn that we have collected personal data from a child outside such an arrangement, we will delete it.

Our approach to AI and your data: We use your inputs (your prompts and any files or content you submit) only to operate the platform and generate the outputs you ask for. We do not use your prompts, inputs, outputs or other personal data to train, retrain, fine-tune, develop or otherwise improve our own or any third party's artificial intelligence or machine-learning models, and we only use AI providers (our "AI sub-processors") whose contractual terms and service settings, as configured by us, do not permit them to use your data for those purposes. This is explained further in paragraph 4 (How your data is processed by AI).

Controller

Foramind Technologies Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

Foramind Technologies Limited is registered in England and Wales, company number 16968436, and is registered with the UK Information Commissioner's Office (ICO), registration no. ZC153961.

Where we provide our services to a business or educational customer (such as a school, college, multi-academy trust or tutoring business) under a subscription agreement, that customer is the controller of the personal data its users submit to our platform, and we process that data on its behalf as its processor. In that case this privacy policy applies only to personal data we process for our own purposes (for example, account administration, billing, security and fraud prevention, and our own marketing), and the customer’s privacy notice applies to the rest.

If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 9), please contact us using the information set out in the contact details section (paragraph 10).

1. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• AI Input and Generated Data includes any personal data, text, prompts, documents, images, or other materials you upload, input, or submit to our AI platform (collectively, "Prompts"), as well as the resulting outputs generated by our AI models.

We also collect, use and share Aggregated and Anonymised Data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends and improve our website and services. This data is stripped of personally identifiable elements so that it does not directly or indirectly reveal your identity. We do not use your Prompts or the content of your inputs or outputs to create this Aggregated and Anonymised Data for model-training purposes.

CRITICAL AI SAFETY NOTE

Please be aware that if you include personal data (or sensitive personal data) within the text prompts you input into the Foramind platform, that data will be processed by our AI models (and by our AI sub-processors) for the sole purpose of generating your outputs. It will not be used to train or improve any AI model. Even so, we strongly advise users not to submit highly confidential, financial, health, or sensitive personal data within raw AI prompts unless strictly necessary for the service.

2. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account on our website or platform;
  • subscribe to our service or publications;
  • input Prompts into our generative AI tools;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website and platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, API telemetry, system logs, and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources.
• Technical Data is collected from the following parties:
  • analytics providers such as Google (Google Analytics), based outside the UK, where you have accepted analytics cookies;
  • sign-in providers such as Google and Apple, where you choose to sign in to our platform with your Google or Apple account; and
  • search information providers.
• Contact, Financial and Transaction Data is collected from providers of technical and payment services.
• Identity and Contact Data is collected from publicly available sources.

3. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud, enhance platform system safety, secure and improve our website and services and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Direct marketing

During the process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from Foramind Technologies Limited via email. You may receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you or by contacting us.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy.

4. How your data is processed by AI

Our platform generates outputs by transmitting your Prompts to one or more artificial-intelligence providers (our AI sub-processors). An AI sub-processor is a third party that provides large language model, generative AI, machine-learning or other AI services to which your inputs are sent for the sole purpose of generating outputs within our Services. This includes any model-routing provider we use and the underlying third-party model providers selected through that provider from time to time. When you use our AI features: Your Prompts are transmitted to the relevant AI sub-processor only to generate the output you have requested. We do not select the content of your Prompts and process them only to provide the Services to you. We do not use your Prompts, inputs, outputs or personal data to train, retrain, fine-tune, develop, optimise or otherwise improve any AI or machine-learning model, nor to create derived profiles or for automated decision-making that produces legal or similarly significant effects on you. Our AI sub-processors may retain Prompts and outputs for a limited period solely for abuse monitoring and legal compliance purposes, in accordance with their terms. At the date of this policy, our AI features use OpenRouter, Inc. (based in the United States) as our model-routing provider and Google's Gemini models as the underlying model provider.

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

• Our group company Zihinler FORA, based in Türkiye, which develops and maintains the Foramind platform, produces learning content and provides customer support on our behalf, acting as our processor.
• Service providers acting as processors who provide IT, system administration services, and foundational AI framework/hosting architecture (including cloud infrastructure providers and third-party large language model (LLM) providers API endpoints being our AI sub-processors described in section 4). Our key service providers at the date of this policy are: Google Cloud (hosting of our platform and the data stored in it, in the United States); OpenRouter, Inc. and Google (AI processing, in the United States); Google Analytics (website analytics, only where you have accepted analytics cookies); and Google and Apple (sign-in services, only where you choose to use them).
• Professional advisers including bankers, auditors and insurers based in the EEA or outside the EEA who provide consultancy, banking, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers (including AI sub-processors) to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Some of our third party service providers and AI sub-processors (including any sub-processors appointed by them) are based outside the UK, so their processing of your personal data, including the transmission of your Prompts to generate outputs, will involve a transfer of data outside the UK. In particular, our platform and the data stored in it are hosted on Google Cloud servers in the United States, Prompts are processed by AI sub-processors in the United States, and members of our group's development and support team who may access personal data are based in Türkiye.

Whenever we (and/or our third party service providers) transfer your personal data out of the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• Your personal data is only transferred to countries that have been deemed to provide an adequate level of protection for personal data.
• The recipient maintains an active certification under the EU–U.S. Data Privacy Framework and the UK Extension to the EU–U.S. Data Privacy Framework (the "DPF"); or
• We (and/or our third party service providers) put in place a specific contract or transfer mechanism approved for use in the UK which gives personal data the same protection it has in the UK, such as the UK International Data Transfer Agreement or Addendum, and/or the EU Standard Contractual Clauses, together with any supplementary measures required to ensure an adequate level of protection.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Where personal data is processed by our third-party service providers (including hosting providers and AI sub-processors), those providers are responsible for the security of their own systems, and we only use providers that give appropriate security commitments. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know (such as system safety teams resolving a critical platform error). They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for up to six years after they cease being customers where this is necessary to meet our legal, tax and accounting obligations or to establish, exercise or defend legal claims. Retention periods for each category of personal data are set out in our data retention schedule, details of which are available on request.

In some circumstances you can ask us to delete your data.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 3 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in paragraph 3 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data's accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us at info@foramind.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: info@foramind.com
• Postal address: 62c Stamford Hill, London, England, N16 6XS
• Data Privacy Manager: can be contacted at info@foramind.com

11. Complaints

You have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us at info@foramind.com or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint.

12. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version is effective from 1 November 2026.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

13. Third-party links

This website and platform may include links to third-party websites, plug-ins, API bridges, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites or applications and are not responsible for their privacy statements. When you leave our website or use external plugins inside our platform, we encourage you to read the privacy policy of every website and tool you visit.