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 (consent-gated) for aggregate visitor behavior. 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^™). Hosting region selected per institution data-residency requirement.
• Microsoft Clarity — consent-gated visitor analytics on the marketing site only; not used inside the SaaS edition portals.
• Frontier model providers — composed into Eve-Education^™ F5/reasoner. The current rotation includes Anthropic Claude (Opus, Sonnet, Haiku), OpenAI GPT, the Meta Llama family (with Llama Vision for diagram and handwritten work analysis), and Microsoft Phi (the proprietary classifier and Small Reasoning Model are Phi-derived). Where an institution or jurisdiction prohibits a specific provider, that provider is swapped out without rebuilding the agent.
• Microsoft Communication Services — for transactional email delivery (account notifications, password reset, certificate delivery) where configured.

Regional data residency

Eve-Grid^™ supports residency-aware deployment. North American institutions are deployed in U.S. Azure regions. European institutions, if any, are deployed in EU Azure regions with EU-Standard-Contractual Clauses for any necessary international transfer. African institutions are deployed in the closest applicable Azure geography (Africa or EMEA), aligned with local data-protection regimes including the Kenya Data Protection Act 2019, Nigeria Data Protection Act 2023, and the East African Community member-state frameworks. Pakistani institutions deploy under Pakistan's national data-handling regime.

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.