Suoni Privacy Policy — privacy-v1

Document identifier reserved: privacy-v1 Effective date: 3 October 2026 Controller: Educational Whiteboards Limited Privacy contact: teachingwhiteboards@gmail.com

1. Who we are

Educational Whiteboards Limited operates Suoni.

For the personal information described in this policy, Educational Whiteboards Limited is the controller unless we state otherwise.

Contact us at teachingwhiteboards@gmail.com for privacy or data-rights requests.

2. Scope

This policy explains how Suoni handles personal information when you use our website, mobile applications, support channels and related services.

The initial controlled release keeps registration and child learner access disabled. If child learner access is introduced later, it will require a separately approved safeguarding and privacy release and may require a new privacy-policy version.

3. Information we may handle

Depending on the features available in the version you use, we may handle:

Account and profile information

This may include name, email address, account or user identifiers, authentication information, profile image, teacher biography, instruments, languages, availability and other profile details.

Lesson and service information

This may include lesson requests, bookings, lesson status, teacher or learner associations, lesson timing, notes, reviews, reports, sheet-music references and related service records.

Messages and user-generated content

This may include messages, support communications, lesson notes, reviews, reports, biographies, uploaded documents, sheet music, images and other content you choose to provide.

Audio and video

Where live lesson or classroom functionality is enabled, camera and microphone data may be transmitted to provide the live session. Suoni does not treat live audio or video as recorded content unless a recording feature is separately enabled and disclosed.

Payment and transaction information

Where payment functionality is enabled, we may handle transaction history, amounts, payment status, payout or withdrawal records and payment-provider identifiers.

We do not need to store full payment-card details where they are processed directly by a regulated payment provider.

Technical, security, device and approximate-location information

This may include IP address, device or installation identifiers, app version, operating system, authentication/security records, logs, crash or diagnostic information and information needed to detect abuse or protect the Service.

Where an enabled analytics or infrastructure provider derives city, region or country from an IP address, Suoni may handle approximate-location information. Suoni does not require precise GPS location for the initial controlled service.

Search and interaction information

When you search for a teacher or instrument, the search text is transmitted to Suoni so that matching results can be returned. Where product analytics is enabled, search and feature-interaction information may also be used to understand and improve the Service.

Support, moderation, privacy and safeguarding information

If you contact us or make a report, we may handle the content of that correspondence and the evidence reasonably necessary to investigate, respond, comply with law or protect users.

Safeguarding evidence may be extracted into a restricted record with tighter access controls where retention is required.

4. Why we use personal information

Depending on the context, we use personal information to:

5. Legal bases

We use personal information only where we have an applicable lawful basis.

For the initial controlled service, the principal bases are:

Optional analytics, live audio/video, new payment flows and push notifications are not enabled merely by listing a possible lawful basis here. If a material new purpose or feature is enabled, we will identify the applicable basis and update our privacy information where required.

We do not rely on this policy to enable child processing. Any child-access release requires a separate approved basis, transparency and safeguarding assessment before activation.

6. Service providers and other recipients

Suoni uses infrastructure and service providers to operate the Service. The providers involved depend on which features are enabled.

These may include:

We may also use providers for hosting, storage, security and operational support where necessary.

The published mailbox currently uses the consumer version of Gmail. Google states that it does not act as a data processor and does not offer a Data Processing Agreement for consumer Gmail; Google's consumer Terms of Service and Privacy Policy apply. Support and rights-request correspondence may therefore also be processed by Google under its own privacy framework.

Other providers may act as our processor/service provider or, for some activities, as an independent controller. Where a provider acts as an independent controller, its own privacy information applies to that processing.

7. Sharing

We do not sell personal information.

We may disclose information:

Where a third party acts as an independent controller, its own privacy notice will apply.

8. International transfers

Some providers may process information outside the United Kingdom.

For Google Cloud / Firebase customer data, Google publishes UK GDPR data-processing terms and contractual transfer mechanisms, including UK controller-to-processor standard contractual clauses where applicable.

The consumer Gmail service used for the published support mailbox is governed by Google's own consumer privacy framework rather than a Suoni processor agreement. Google states that information may be processed on servers outside the country where the user lives and publishes transfer mechanisms including adequacy arrangements, the UK Extension to the EU-U.S. Data Privacy Framework where applicable, and standard contractual clauses where required.

For any other restricted international transfer for which Suoni is responsible, we use an appropriate safeguard or another transfer basis recognised by UK law.

9. Retention

We keep personal information only for as long as it is reasonably needed for the purpose for which it was collected and for applicable legal, security, accounting, dispute or safeguarding requirements.

Current controlled retention decisions include:

A legal hold, active dispute, fraud/security investigation or legal requirement may justify a longer period for a defined record.

Adult financial and accounting retention is managed separately from child identity retention.

10. Account deletion

If you have a Suoni account, you can request deletion through an available in-app deletion option or through Suoni's published account-deletion web page. You can also contact teachingwhiteboards@gmail.com for assistance with a deletion request. We may ask for information reasonably necessary to verify that the request relates to your account.

A valid deletion request does not necessarily erase every record immediately. We may retain or pseudonymise information where required for legal obligations, accounting, security, safeguarding, fraud prevention, dispute handling or proof that a deletion request was completed.

The account-deletion process removes or scrubs active authentication/private account state and preserves controlled evidence that the deletion request was carried out. Historical records involving another user, financial/accounting records, safeguarding evidence or records subject to a legal hold may be retained only where there is a legitimate reason to do so.

11. Security

We use technical and organisational measures designed to protect personal information, including access controls, encryption where appropriate, restricted evidence stores, logging and controlled release processes.

No internet service is completely secure. If you believe your Suoni account or information has been compromised, contact us promptly.

12. Children

Child learner registration and child access are disabled in the initial controlled release.

Before any child-access release, Suoni requires additional safeguarding, continuity, service-hours, age/guardian, transparency and store-policy controls.

A later child-access release may require a new immutable Privacy Policy identifier rather than modifying privacy-v1 in place.

13. Automated decision-making

Suoni does not use solely automated processing to make decisions that produce legal or similarly significant effects on users in the initial controlled release.

14. Your rights

Depending on the circumstances, UK data-protection law may give you rights to:

These rights are subject to legal conditions and exceptions.

To exercise a right, contact teachingwhiteboards@gmail.com.

You may also complain to the UK Information Commissioner's Office if you believe your data-protection rights have been infringed.

15. Changes to this policy

Material changes will use a new immutable policy version. We will not silently replace the published body associated with privacy-v1.

16. Company information and contact

Educational Whiteboards Limited Company number: 14554635 Registered in: England and Wales Registered office: Educational Whiteboards Limited, 124 City Road, London, England, EC1V 2NX Email: teachingwhiteboards@gmail.com