Executive summary
Xeropan's Commitments Regarding Children's Data and Artificial Intelligence
Xeropan is committed to the responsible processing of children's data, the ethical use of educational technology, and the transparent deployment of artificial intelligence within the Platform.
The following principles apply to the institutional use of the Platform:
1. We do not sell Learners’ personal data
Xeropan does not sell, rent, or otherwise monetize Learners' Personal Data by disclosing it to third parties for commercial purposes.
2. We do not use Learner data for targeted advertising
Learners' Personal Data is not used to deliver targeted advertising or behavioral advertising.
3. We do not profile Users for marketing purposes
The Platform does not use User data to create marketing, advertising, or commercial profiles of minors.
4. Human oversight remains essential
AI-enabled features are designed to support learning and communication development. They do not replace the professional judgment of Teachers, educational institutions, parents, legal guardians, or other qualified professionals.
5. AI does not grade or make disciplinary decisions
AI-enabled features are not used as the basis for official grading, admissions decisions, disciplinary actions, certification decisions, or other formal educational determinations.
6. Learner data requests are managed through the institution
Learners and, where applicable, their parents or legal guardians may request access, rectification, export, restriction, or deletion of Personal Data through the Institution acting as Controller, subject to applicable law.
7. Personal data is used for educational purposes
Personal Data processed through the Platform is used primarily to support learning activities, provide the Services, maintain the Platform, and facilitate institutional administration.
8. Child safety concerns may be reported
Concerns relating to child safety, data protection, AI usage, or the use of the Platform may be reported through the Institution or directly to Xeropan.
Contact Information:
1. Purpose of this Statement
1.1. The purpose of this Transparency, Artificial Intelligence and Child Safeguarding Statement is to provide clear and accessible information regarding the operation of AI-enabled features within the Xeropan Platform, their intended purposes, limitations, child safeguarding principles, and the related data protection commitments.
2. The role of AI in the platform
2.1. Xeropan may utilize artificial intelligence technologies within certain Platform features.
2.2. The primary purposes of AI-enabled features include:
2.2.1. supporting language learning;
2.2.2. developing communication skills;
2.2.3. facilitating speaking practice;
2.2.4. providing educational feedback;
2.2.5. enabling interactive language-learning activities.
2.3. AI-enabled features are designed to support educational activities and do not replace the professional judgment of Teachers, educational institutions, or other qualified professionals.
3. What AI is not used for?
3.1. AI-enabled features are not intended for:
3.1.1. official examinations or testing;
3.1.2. determining academic grades or formal assessments;
3.1.3. admissions decisions;
3.1.4. disciplinary decisions;
3.1.5. legal, governmental, or regulatory decision-making;
3.1.6. automated decision-making within the meaning of Article 22 GDPR.
3.2. Outputs generated by AI-enabled features are advisory and supportive in nature only.
4. Human oversight
4.1. Xeropan recognizes that human professional judgment remains essential in educational environments.
4.2. Accordingly:
4.2.1. Teachers retain ultimate responsibility for educational decisions;
4.2.2. institutional policies and educational procedures continue to apply;
4.2.3. AI-generated outputs may require human review and validation where appropriate.
4.3. The Institution remains responsible for determining which educational processes require human oversight, review, or approval.
5. Limitation of AI systems
5.1. AI systems may generate outputs that are inaccurate, incomplete, inconsistent, misleading, or otherwise unsuitable for a particular purpose.
5.2. Accordingly, Xeropan does not warrant that:
5.2.1. all AI-generated outputs will be error-free;
5.2.2. all AI-generated outputs will be complete;
5.2.3. all AI-generated outputs will be pedagogically, linguistically, or educationally optimal or appropriate.
5.3. AI-generated outputs should be treated as informational and supportive content only.
6. Processing of data in connection with AI features
6.1. When AI-enabled features are used, the Platform may process:
6.1.1. text inputs;
6.1.2. speech-based interactions;
6.1.3. language-learning responses;
6.1.4. contextual learning information relevant to the educational interaction.
6.2. Further details regarding Processing activities associated with AI-enabled features are set out in Annex 5 of the DPA.
6.3. All Processing of Personal Data is carried out in accordance with applicable Data Protection Laws.
7. Third-party AI service providers
7.1. Xeropan engages third-party providers of artificial intelligence technologies in connection with the provision of AI-enabled features.
7.2. Such providers:
7.2.1. operate under contractual obligations;
7.2.2. may qualify as Subprocessors under the DPA;
7.2.3. may process Personal Data only to the extent necessary to provide the relevant services.
7.3. The current list of Subprocessors is available in Annex 3 of the DPA.
8. Model training and AI development
8.1. Xeropan does not use Personal Data provided by the Institution for the training, development, or improvement of Xeropan-owned artificial intelligence models.
8.2. Where OpenAI services are used as part of the Platform, Personal Data provided by the Institution is not used by Xeropan to train or develop Xeropan-owned AI models.
8.3. OpenAI services are used solely to the extent necessary to provide AI-enabled educational functionality within the Platform.
9. Protection of children’s data
9.1. The intended use of the Platform does not require the Processing of Sensitive Data within the meaning of Article 9(1) GDPR.
9.2. Xeropan processes Learner data only to the extent necessary to provide institutional services and operate the Platform.
9.3. Learner Personal Data is not sold and is not used for marketing, advertising, or commercial profiling purposes.
10. Child safeguarding principles
10.1. Xeropan seeks to ensure that its services:
10.1.1. support a safe digital learning environment;
10.1.2. encourage responsible technology use;
10.1.3. serve educational purposes;
10.1.4. take into account the best interests of children.
10.2. Primary responsibility for decisions affecting children remains with parents, legal guardians, Teachers, educational institutions, and other responsible adults.
11. Online safety
11.1. Xeropan implements and maintains appropriate technical and organizational measures designed to support the safe use of the Platform.
11.2. Xeropan may remove, restrict, or disable content that is unlawful, harmful, or presents a security risk to the Platform or its Users.
12. Transparency
12.1. Xeropan seeks to make material information regarding the operation of AI-enabled features available to Institutions and Users in a clear and accessible manner.
12.2. Xeropan may periodically review the operation of AI-enabled features and assess their educational, ethical, safety, and data protection impacts.
13. Concerns, complaints and reports
13.1. Concerns relating to:
13.1.1. data protection;
13.1.2. information security;
13.1.3. artificial intelligence;
13.1.4. child safeguarding;
13.2. may be reported through the following channels: info.en@xeropan.com
14. Related documents
14.1. This Statement should be read together with the following documents:
14.1.1. Institutional Services Agreement (ISA);
14.1.2. Data Processing Agreement (DPA);
14.1.3. Institutional Terms of Use (TOU).
15. Final provisions
15.1. This Transparency, Artificial Intelligence and Child Safeguarding Statement is provided for informational purposes only.
15.2. Binding obligations relating to the Processing of Personal Data are governed by the DPA. Contractual rights and obligations relating to the provision of the Services are governed by the ISA.
15.3. Xeropan may periodically review, update, and amend this Statement to reflect changes in the Platform, applicable laws, regulatory guidance, or industry best practices.