NAIGURU, S.L., (hereinafter, the "Company") is committed to protecting Users privacy. Through this privacy policy (hereinafter, the "Privacy Policy") we inform you how the Company processes the personal data that we obtain within the framework of the activity of this platform (hereinafter, the "Platform").
“Users” are defined under section 3 of this Privacy Policy and also referred to as “you”.
The Company is the data controller of the personal data indicated in this Privacy Policy, which implies that we are responsible for taking care of the privacy of the personal data of the Platform. We will use your personal data fairly, lawfully and transparently and in accordance with the relevant regulations.
Our contact details are as follows:
If you have any questions about this section, or any aspect related to the processing of personal data, you can contact the person responsible for privacy matters of the Company at the email address indicated above.
If your school (hereinafter, the "School") has registered you (either a Student User or as a Teacher User) on the Platform, the School is solely responsible for processing your personal data within the Platform. This means that any processing of your personal data follows the School’s privacy policy, and the School assumes full responsibility and risk for that processing.
In this scenario, the Company acts only as a data processor, following the School’s instructions.
If you wish to exercise your data protection rights as described in section 9, you must contact your School directly, as it is responsible for responding to such requests.
Please consult your School directly for additional information regarding their processing of your personal data.
The Company will only act as a data controller for the purpose of securing the data by its anonymisation. Once anonymised, the data may be used indefinitely to improve the Platform and its services.
If you (or the Student User Parent/Guardian) have created your own account on the Platform and were not registered by a School, then the Company is the only organisation responsible for processing your personal data. In this case, we act as the data controller, as we have a direct relationship with you according to the Platform's Terms and Conditions.
By reading this Privacy Policy, the user (hereinafter, the "User" or "Users") is informed about the circumstances in which their personal data will be processed. Within the Platform we must distinguish the following categories of Users:
The data requested through the forms are generally mandatory (unless otherwise specified in the required field) to comply with the purposes for which they are being collected.
Therefore, if they are not provided or are not provided correctly, we will not be able to properly deal with your request.
This is the data you provide to us by filling in forms on the Platform, or through any interaction you make on the Platform.
Identification data: name and surname, email, date of birth, and profile picture.
Communication data: messages about queries relating to the Platform or its services and any data you provide to us when you contact us.
Data related to the services of the Platform: among which you can find the following:
Payment data (18+ only): billing details (billing name and address, country), purchase and subscription details (plan, amount, currency, renewal date), invoices/receipts, VAT/tax information (where applicable), payment status, and transaction/payment reference identifiers. Card details are processed by our payment provider; we do not store full card numbers or CVV/security codes.
Identification data: Email
Communication data: messages about queries relating to the Platform or its services and any data you provide to us when you contact us.
Payment data: billing details (billing name and address, country), purchase and subscription details (plan, amount, currency, renewal date), invoices/receipts, VAT/tax information (where applicable), payment status, and transaction/payment reference identifiers. Card details are processed by our payment provider; we do not store full card numbers or CVV/security codes.
Identification data: name and surname, professional email, profile picture.
Communication Data: messages about queries relating to the Platform or its services and any data you provide to us when you contact us.
Data related to the services of the Platform: among which you can find the following:
If any User provides personal data belonging to third parties for any purpose, you confirm that you have previously informed the individuals concerned and obtained their explicit consent to share their data with the Company.
If the personal data provided relates to minors, you guarantee that you are legally authorised to do so. This includes having obtained the consent of the individuals holding parental authority or legal guardianship, as required.
You also confirm that the information provided is accurate and truthful.
The Company reserves the right to verify the consent of the affected individuals by sending a non-commercial email requesting confirmation of the authorisation you have declared.
If any liability arises due to a breach of these conditions, you will be solely responsible for the consequences.
We will process your personal data for the following purposes:
Purpose
Legal basis
The development of the existing pre-contractual and/or contractual relationship.
Or, where permitted under applicable data protection laws the legitimate interest in efficiently managing the business and fulfilling our contractual obligations with the Schools.
Purpose
So that we can provide you with the artificial intelligence-powered services of the Platform (on behalf of the Company or where applicable, the School) and comply with our Terms and Conditions.
For example, we process data related to the questions and exercises completed by Users, as well as their interactions with the AI-powered virtual tutor, in order to provide relevant responses and support based on their requests.
Please note that all answers and corrections provided by the virtual AI tutor are generated automatically by artificial intelligence systems, without human intervention. These interactions are designed to help Users improve their math skills and are based on data sourced from official exams and textbooks.
Legal basis
The development of the existing contractual relationship.
Or, where permitted under applicable data protection laws the legitimate interest in efficiently managing the business and fulfilling our contractual obligations with the Schools.
Purpose
For example, we will process data from exercises performed by Users and their interactions with the AI tutor to improve the performance and capabilities of the AI tutor and identify optimal teaching methodologies.
Legal basis
The development of the existing contractual relationship.
Or, where permitted under applicable data protection laws the legitimate interest in efficiently managing the business.
Or, where permitted under applicable data protection laws the legitimate interest in optimising the operation and quality of the Platform and its services.
Purpose
Legal basis
Legal obligation.
The development of the existing pre-contractual and/or contractual relationship.
Or, where permitted under applicable data protection laws the legitimate interest in efficiently managing the business.
Purpose
Legal basis
The legitimate interest in optimising the operation and quality of the Platform and its services.
Or, where required under applicable data protection laws, consent.
We do not share your personal data with other organisations without your express consent, except in the following circumstances:
International data transfers may be made to the United Kingdom, as this is where our Amazon Web Services servers are hosted. Data transfers to the United Kingdom will be made in accordance with applicable data protection laws, including the European Commission's adequacy decision of 28 June 2021 (Implementing Decision (EU) 2021/1772).
Any other transfer to other countries that are not considered secure will be made by protecting your data through the appropriate guarantees in accordance with the applicable regulations, which may consist of the signing of Standard Contractual Clauses including those approved by the European Commission between the exporter and the importer of data.
You can request additional information from the Company at the email address indicated in the first section of this Privacy Policy.
Your personal data will be kept for as long as necessary to fulfil the purposes we collected it for, or until you exercise your right to object, delete, limit processing, and/or revoke your consent, as appropriate.
In addition, once the relationship with you has ended, your data will not be kept unless we are required to keep such data for regulatory compliance purposes, or in case of potential claims.
You may (i) send a letter to the Company, at the postal address indicated in the header; or (ii) send an email to the address info@materact.com, identifying themselves and specifying the exercise of one or more of these rights. In the event that the Company has reasonable doubts about your identity, it may request a photocopy of your ID card or other equivalent document to confirm your identity. You can exercise your rights at any time and free of charge.
Subject to applicable data protection laws, and any exceptions or conditions thereunder, you may be able to exercise certain rights such as:
In any case, if you consider that your data protection rights have been violated and/or that the Company does not comply with its obligations in terms of privacy, you may file a complaint with your competent data protection authority.
We remind you that if your registration on the Platform has been made at the request of your School, you must exercise your rights through the School.
We may update our Privacy Policy from time to time.
We will notify you by email and/or by means of a prominent notice through the Platform, prior to the change becoming effective, and we will update the "Last Update" date at the bottom of this Privacy Policy.
We advise you to review the Privacy Policy periodically for any changes. Changes are effective when they are posted on the Platform.
LAST UPDATE: 03/03/2026
