For Data Protection Officers · One-page summary

Data Protection Summary

The Business School · TBS Education Ltd Oy · Version 1.0, September 2026. Effective 28 April 2026

Controller / Processor

School = Data Controller. TBS Education Ltd Oy = Data Processor.

Lawful basis

Legitimate interest of the school (curriculum-aligned education) under UK GDPR Art. 6(1)(f).

UK Data Protection Registration
ICO Registration: ZC133810

Verifiable on the ICO public register at ico.org.uk.

What we collect

Data typeDetail
TeacherName, email, school name, session history
StudentSelf-selected nickname only (no real name, no email, no DOB, no photos). PIN-code join, no account, no password.
GameplayIn-session decisions (purchases, pricing, VAT filing, hiring) and team scores
TechnicalIP address (server logs only, 30-day auto-purge); browser/device headers; session timestamps

Where it is stored

Sub-processorPurposeLocationSafeguard
NetlifyFrontend hosting + edge CDNGlobal edge; primary EU edgeSCC (UK Addendum)
NeonPostgres databaseAWS US East 1, EU migration planned May 2026SCC (UK Addendum); AES-256 at rest; TLS 1.2+ in transit
OpenAIAI inference for end-of-session reports (Claude API)EU and US regionsSCC (UK Addendum); no student personal identifiers sent to model

Retention

Free tier sessions: deleted after 30 days. Paid tier saved sessions: teacher-controlled deletion. Teacher accounts: retained during subscription, deleted within 30 days of termination. Server logs (IP): 30 days, auto-purged.

Sharing

No sale, no rental, no advertising profiling. The three sub-processors above process data solely to deliver their infrastructure or inference services. No marketing tracking cookies. PIN-code join eliminates credential risks.

Rights and complaints

Under UK GDPR / EU GDPR: rights of access, rectification, erasure, restriction, portability, and objection. Student data requests are routed via the school as Data Controller. Complaints to the UK ICO at ico.org.uk/concerns or to the Finnish Data Protection Ombudsman at tietosuoja.fi.

Contact

Sakari Laajoki, TBS Education Ltd Oy · support@thebusiness.school · Response within 72 hours. Full Privacy Policy and Data Processing Agreement available at thebusiness.school/data-protection.