GDPR & Data Sovereignty

Data Architecture

The BlueberryML manifold reaches schools through ClassGrade deployments, each operated by a licensee as data controller and data processor on their own infrastructure under their own jurisdiction's law. BlueberryML licenses the manifold and the code that runs it, and is not in the data path.

What Crosses the Boundary

When BlueberryML licenses the manifold, the artefact that ships is trained geometry: learning outcomes, prerequisite structure, progression gates, and activity mappings. No student records, no learning trajectories, no transcripts, and no audio travel with it — there is nothing in the artefact that could identify or reconstruct a learner. Personal data stays in-region with the licensee, on the licensee's infrastructure, under the licensee's jurisdiction.

ClassGrade Deployments

Under the ClassGrade pattern, no student data, audio, transcripts, exam images, or assessment signals flow from the licensee's infrastructure to BlueberryML's infrastructure. The licensed code runs locally on the licensee's systems, processes data locally, stores results locally, and never phones home. Each deployment publishes its own privacy notice and data-handling terms under its own brand and jurisdiction.

The arrangement between BlueberryML and a ClassGrade licensee is technology licensing, not data processing. No DPA is required because BlueberryML does not process licensee data.

Zero Training on Student Data

The licensed code does not train AI models on student data. Student conversations and learning records are used only to personalise the individual student's learning path. This applies across every deployment that runs the manifold.

This Website

blueberryml.com is a corporate website. We collect basic website analytics and contact-form enquiries. No student data is collected or processed on this site. For website-level privacy, see the Privacy Policy.

Enquiries

For BlueberryML-level data questions, contact [email protected]. For ClassGrade deployment data questions, contact the operating licensee.