Privacy Policy & Student Data Protection

1. Data Controller & Commercial Operations

The entities responsible for data control and commercial distribution of EvaGrade are:

• Author & Creator of the Software: Rubén Cancho Gasulla (EvaGrade Software).
• Commercial Distribution & Billing: International distribution and official invoicing managed from London (United Kingdom) via Lemon Squeezy, LLC (Merchant of Record).
• Privacy & DPO Inquiries: [email protected]

2. Architecture & Student Privacy (FERPA, COPPA, GDPR)

Unlike cloud SaaS tools that ingest and store student submissions on third-party servers, EvaGrade operates strictly locally:

• Local SQLite Storage: All course data, draft rubrics, and feedback are saved in a local SQLite database directly on your computer's drive. EvaGrade operates no backend databases containing student submissions.
• 100% Offline Local AI (Ollama): When using local AI models, all inference runs on your machine's CPU/GPU without sending any data over the internet.
• Pre-Request Anonymization Pipeline: When optionally connecting cloud AI APIs (such as OpenRouter or Gemini), EvaGrade automatically anonymizes student names, emails, and student IDs before dispatching prompts to the AI provider.
• Direct Moodle Connectivity: All sync requests and grade publications travel directly between your machine and your school's Moodle instance via encrypted TLS connections.

3. Information We Collect and Purpose

A. Orders & Billing Data (Lemon Squeezy)

When purchasing an EvaGrade license, your payment information (name, email address, country, postal address, and payment method details) is processed directly by our authorized Merchant of Record, Lemon Squeezy, LLC. EvaGrade never has access to or stores your credit card numbers.

B. License Key Verification

When activating your license, our licensing server receives only the license key, your customer email, and an irreversible cryptographic machine identifier to ensure compliance with the 3-device seat limit.

C. Early Access & Waitlist Data

If you voluntarily sign up for our early access waitlist by providing your email address and educational tier, we use this information exclusively to notify you when EvaGrade is released, send your free trial access, and deliver founder benefits. You may unsubscribe or request data deletion at any time with 1 click or by emailing [email protected].

4. Legal Basis for Processing

• Performance of a Contract: To deliver software license keys, authenticate active subscriptions, and deliver updates.
• Legal Obligations: Compliance with mandatory tax, accounting, and commercial reporting regulations.
• Legitimate Interests: Providing technical assistance and preventing fraudulent license misuse.

5. Your Privacy Rights

Under applicable data protection laws (including GDPR and international standards), you have the right to:

• Access the personal and license information associated with your account.
• Request correction of inaccurate contact details.
• Request deletion ("Right to be Forgotten") of your customer record.
• Restrict or object to processing under certain circumstances.
• Data portability of your customer account data.

To exercise any of these rights, email us at [email protected]. We respond to all requests within 30 days.

6. Website Cookies

Our website (evagrade.com) only uses essential technical cookies required for language preferences, navigation, and the Lemon Squeezy checkout modal. We do not use advertising cookies, invasive tracking pixels, or third-party marketing trackers.

7. Security Measures

We employ industry-standard security safeguards, including TLS 1.3 encryption across all website and license verification endpoints, ensuring your data remains secure and confidential.

8. Contact

For any privacy questions or requests, please contact our team at [email protected] or visit our Contact Page.