Effective date: September 2026
Last updated: September-2026
Introduction
This privacy policy applies to all mobile applications developed and operated by Symphony of Knowledge Sociedade Unipessoal, Lda, that link to or reference this Privacy Policy (collectively, the “Apps”). The App currently covered by this Privacy Policy includes PathwayIQ.
This Privacy Policy explains how Symphony of Knowledge Sociedade Unipessoal, Lda, (“we”, “us”, or “our”) collects, uses, stores, and protects information when you use our apps.
We are an EdTech R&D organisation focused on advancing Adaptive Learning Systems; therefore, our Apps are educational technologies that encompass intelligent, real-time learning systems and digital learning platforms that provide adaptive academic guidance, admission-readiness assessment, and effective study strategies, helping students better understand their academic pathway, strengths, areas for development, and prepare for university admissions.
1. Information We Collect
Depending on how you use our Apps, we may collect:
- Account information: name, email address, login details, and account preferences.
- Student profile information: educational interests, goals, intended programmes, and other information relevant to education voluntarily provided by the user.
- Academic information: grades, courses, qualifications, academic history and other educational records entered or uploaded by the user.
- Assessment information: responses to assessments, diagnostic activities, SOP-related exercises, readiness scores, feedback and recommendations.
- AI interactions: questions, prompts, responses and other information submitted to or generated through our App’s AI-powered features.
- Usage and technical information: device information, browser type, IP address, session information and interaction data.
- Analytics information: information about how users interact with the App, which may be used to improve its functionality and educational effectiveness.
We encourage users not to submit unnecessary sensitive personal information.
2. How We Use Information
Information provided is used to:
- provide personalised and adaptive academic guidance;
- assess and communicate admission-readiness levels;
- generate learning pathways, recommendations and feedback;
- support AI-powered assessment and scaffolding features;
- maintain and manage user accounts;
- improve the accuracy, usability, and educational value of our Apps;
- conduct educational research, testing and product development where appropriate;
- maintain security, prevent misuse and comply with legal obligations.
Our Apps are designed primarily to support student decision-making in areas of uncertainty in their education journey and career development.
3. AI-Powered Features
Some of our Apps use artificial intelligence to analyse information provided by users and generate personalised guidance, assessments, feedback, and recommendations.
AI-generated outputs may not always be accurate or complete. They should therefore be treated as guidance rather than definitive academic, admissions, or career decisions.
Where third-party AI services are used to process information, relevant data may be transmitted to those service providers solely as necessary to provide the requested functionality and subject to applicable contractual and data-protection safeguards.
4. Adaptive Personalisation
Our Apps may use a user’s profile, academic information, assessment responses and interactions to adapt questions, feedback, scaffolding, recommendations and learning pathways.
This process is intended to provide more relevant, personalised educational support. Users should not rely solely on AI-generated analyses or recommendations when making significant academic or university decisions.
5. Analytical and Research
We may use aggregated, anonymised or appropriately protected information to understand how our Apps are being used and to support educational research, evaluation and product improvement.
Where information is used for research or analytics beyond what is necessary to provide the service, we will apply appropriate safeguards and, where required, obtain the relevant consent or establish another lawful basis.
6. Data Sharing
We do not sell users’ personal information.
We may share information with:
- technology and service providers, including hosting, cloud, analytics, security, communications, and AI service providers that process information on our behalf.
- professional advisers or authorities where legally required.
When applicable, we require service providers handling personal information on our behalf to apply appropriate confidentiality and security measures.
7. Data Security
We use reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.
However, no internet-based service can guarantee absolute security.
8. Data Retention and Deletion
We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including providing the service, maintaining records, improving our Apps, resolving disputes and meeting legal obligations.
Retention periods vary depending on the type of information and the purpose for which it is used. When personal information is no longer required, we will delete it, anonymise it, or securely dispose of it, subject to applicable legal and regulatory requirements.
Where applicable, you may request deletion of your personal information. Certain information may need to be retained where required or permitted by law, or where necessary to establish or defend legal claims.
9. Your Rights
Subject to applicable law, users may have the right to:
- access the personal information we hold about them;
- request correction of inaccurate information;
- request deletion of their information;
- request restriction of certain processing;
- object to certain processing;
- withdraw consent where processing is based on consent;
- request a copy of their information in a portable format.
Requests may be submitted using the contact details below.
10. Children and Young Users
Some of our Apps may be used by students who are under the age of majority. Where applicable, we will comply with laws governing the collection and processing of children’s personal information and obtain parental or guardian consent where required.
11. International Data Transfer
Some of our technology or AI service providers may process information outside your country or the European Economic Area. Where applicable, we will use appropriate legal safeguards for international transfers as required by applicable data protection law.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes to our Apps, our practices, or applicable legal requirements. The updated version will be published on this page with a revised “Last updated” date.
13. Contact Us
If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact:
Symphony of Knowledge Sociedade Unipessoal, Lda
Email: policy@symphonyofknowledge.com
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