1. Who We Are

The Study Floor is operated by Townhouse Education Ltd (“we”, “our”, “us”). We are the data controller for personal information collected through The Study Floor website and applications.

2. Information We Collect

We may collect:

• name;
• email address;
• account details;
• billing information;
• device information;
• IP address;
• usage data;
• educational information you choose to upload;
• communications with us;
• AI interactions and prompts.

3. How We Use Information

We use information to:

• provide Services;
• manage accounts;
• process payments;
• improve platform functionality;
• develop AI features;
• provide customer support;
• prevent fraud and abuse;
• comply with legal obligations.

4. Legal Basis

We process personal data under one or more of the following legal bases:

• contract performance;
• legitimate interests;
• legal obligations;
• consent where required.

5. AI Processing

User inputs may be processed using AI systems to generate educational responses and improve platform functionality.

We do not use personal data for model training unless permitted by law and disclosed to users.

6. Data Sharing

We may share information with:

• payment providers;
• cloud hosting providers;
• analytics providers;
• professional advisers;
• regulators and authorities where legally required.

We do not sell personal data.

7. International Transfers

Where personal data is transferred outside the UK, we implement appropriate safeguards as required by UK GDPR.

8. Data Retention

We retain personal data only as long as necessary for legitimate business and legal purposes.

9. Your Rights

Subject to applicable law, you may:

• access your data;
• correct inaccurate data;
• request deletion;
• restrict processing;
• object to processing;
• request portability;
• withdraw consent.

10. Security

We implement reasonable technical and organisational measures to protect personal information. No system can guarantee absolute security.

11. Children

Users under 18 should only use the Services with appropriate parental or guardian consent.

12. Contact

Privacy enquiries should be directed to:

hello@thestudyfloor.co.uk
Townhouse Education Ltd
3rd Floor
86–90 Paul Street
London
EC2A 4NE

13. Complaints

You have the right to complain to the UK Information Commissioner’s Office (ICO).

14. Changes to this Policy

We may update this Privacy Policy periodically. Updated versions will be published on our website.

Data Processing Addendum (DPA)

Effective Date: June 2026

This Data Processing Addendum forms part of the agreement between Townhouse Education Ltd, trading as The Study Floor (“Processor”) and the organisation, tutor, school, college, academy, educational business or other customer using the Services (“Controller”).

1. Purpose

This DPA governs the processing of personal data by The Study Floor on behalf of the Controller.

2. Definitions

Controller, Processor, Personal Data, Data Subject, Processing, Personal Data Breach and Special Category Data shall have the meanings given in UK GDPR.

3. Roles of the Parties

The Controller determines:

• the purposes of processing;
• the categories of personal data processed;
• the lawful basis for processing.

The Study Floor acts as a Processor solely on behalf of the Controller.

4. Subject Matter of Processing

The Study Floor processes personal data for the purpose of providing educational software services, including:

• account administration;
• educational content delivery;
• AI-assisted learning services;
• progress tracking;
• communication features;
• reporting and analytics.

5. Categories of Data

Depending on usage, personal data may include:

• names;
• email addresses;
• usernames;
• educational information;
• attendance information;
• assessment data;
• uploaded documents;
• communications data;
• usage information.

6. Controller Responsibilities

The Controller warrants that:

• it has a lawful basis for processing personal data;
• all necessary notices have been provided;
• appropriate consent has been obtained where required;
• data subjects’ rights are respected.

7. Processor Obligations

The Study Floor shall:

1. process personal data only on documented instructions;
2. ensure confidentiality of personnel;
3. maintain appropriate technical and organisational measures;
4. assist the Controller in responding to data subject requests;
5. assist with security and breach obligations;
6. notify the Controller without undue delay after becoming aware of a Personal Data Breach;
7. make information reasonably necessary to demonstrate compliance available upon request.

8. Security Measures

The Study Floor maintains security measures including, where appropriate:

• encrypted transmission of data;
• password protection;
• access controls;
• monitoring and logging;
• secure hosting infrastructure;
• vulnerability management processes.

No system can guarantee absolute security.

9. Sub-Processors

The Controller authorises The Study Floor to engage sub-processors as reasonably required to provide the Services. Examples may include:

• cloud hosting providers;
• analytics providers;
• customer support platforms;
• payment processors;
• communication providers.

The Study Floor shall ensure appropriate contractual safeguards are maintained.

10. International Transfers

Where personal data is transferred outside the United Kingdom, The Study Floor shall implement appropriate safeguards required under UK GDPR.

11. Data Subject Rights

The Study Floor shall provide reasonable assistance to enable the Controller to respond to:

• access requests;
• rectification requests;
• erasure requests;
• restriction requests;
• portability requests;
• objection requests.

12. Data Breaches

The Study Floor shall notify the Controller without undue delay after becoming aware of a Personal Data Breach affecting data processed under this DPA.

13. Audits

The Controller may request reasonable information demonstrating compliance. Any audit must:

• be reasonable;
• not disrupt operations;
• occur during normal business hours;
• be subject to confidentiality obligations.

14. Deletion or Return of Data

Upon termination of Services and written request, The Study Floor shall:

• delete personal data; or
• provide a reasonable export of available data;

unless retention is required by law.

15. Liability

Each party’s liability under this DPA shall be subject to the limitations contained within the Terms of Service unless prohibited by applicable law.

16. Governing Law

This DPA shall be governed by the laws of England and Wales.

17. Contact

Data protection enquiries should be directed to:

hello@thestudyfloor.co.uk
Townhouse Education Ltd
3rd Floor
86–90 Paul Street
London
EC2A 4NE
United Kingdom