No customer data is ever used for training.

Processing roles

For institutional deployments, the institution is the data controller for personal data and the holder of education records under FERPA. Eve-Education, LLC is the data processor under Article 28 GDPR (and analogous state-law constructs) and the school official under FERPA, processing data only on documented instructions from the controller.

Categories of data

• Identity data. Names, institutional email addresses, role within the institution, identifiers issued by the institution. Provided by the institution; not collected from the learner directly.
• Educational records. Course enrollment, lesson progress, assessment artifacts, learning-profile data, AI-assisted output reviewed by the educator. Held under FERPA where applicable.
• Reasoning telemetry. Aggregated structured-workflow telemetry required to operate the platform — error rates, latency, queue depth, and workflow completion. No content of educational records is collected as telemetry.
• Marketing-site form submissions. Talk-to-Sales and PLE waitlist submissions on arthurgrid.ai. Stored only as long as needed to respond and route to the appropriate person.
• Marketing-site analytics. Microsoft Clarity for aggregate visitor behavior. It does not load for visitors in the EU or UK unless they allow it with “Your Privacy Choices” in the footer; elsewhere it loads by default and can be turned off there. Microsoft Application Insights (operational) for performance and errors. Neither is used for behavioral profiling.

Subprocessors

ArthurAI^™ uses a deliberate, minimal subprocessor stack. Each subprocessor is engaged under a contract that includes appropriate technical and organizational measures. The full list is disclosed at institutional onboarding and updated under change-control.

• Microsoft Azure — infrastructure substrate (Eve-Grid^™). West US 2 (United States) for every edition. The full list, including payment, sign-in and enquiry services, is on the subprocessors page.
• Microsoft Clarity — visitor analytics on the marketing site, the ArthurAI^™ FLE parent sign-up and checkout pages, Studio and the PLE admin (visitors can turn it off with “Your Privacy Choices”); never in a learner or child session.
• Microsoft Corporation — Azure AI Foundry — the processing entity for AI inference. Hosts and executes the compact classifier, the fine-tuned Small Reasoning Model, and the general-purpose generation, vision, and long-context components composed into Eve-Education^™ F5/reasoner, including the long-context vision path used for diagram and handwritten-work analysis. The Foundry service is in East US 2; its model deployments are Azure global deployments, which Microsoft documents may process requests in any Azure region, while data they store at rest stays in the United States geography. No use of inputs or outputs for model training, under the Microsoft Online Services DPA (aka.ms/dpa). No AI request goes to any other company.
• Microsoft Communication Services — for transactional email delivery (account notifications, password reset, certificate delivery) where configured.

Where your data is

All ArthurAI™ production data is stored in the United States: the application, databases and files in Microsoft Azure West US 2, with database backups for the main platform also in the paired region West Central US. AI processing runs on Microsoft Azure AI Foundry global deployments, which Microsoft documents may process requests in any Azure region, while data they store at rest stays in the United States geography. Hosting in another region is built on request for an institution that needs it; no other region is in use today. Transfers from outside the United States are covered by our data processing agreement.

• Application, databases and file storage (every edition): Microsoft Azure, West US 2 (United States)
• Database backups: Main platform and PLE databases: geo-redundant to the Azure paired region, West Central US (United States), kept 35 days. Studio database: kept 7 days in West US 2
• AI processing (Azure AI Foundry): Microsoft Azure global deployments: the service is in East US 2 (United States), and Microsoft documents that requests on global deployments may be processed in any Azure region; Microsoft documents that data stored at rest for them stays in the United States geography
• Transactional email (Azure Communication Services): United States
• Content delivery and web application firewall (Azure Front Door): Microsoft global edge network

Measured from our Azure resource inventory on 2026-10-08.

Retention

Educational records are retained per the institution's contracted retention period, in line with the institution's record-retention policy and applicable statute. Audit logs are retained for a minimum of 7 years for FERPA-covered deployments. Marketing-site form submissions are retained for the period required to respond and route to the appropriate person, then deleted on a defined cadence unless the submission becomes a customer record.