Data Processing Agreement

This agreement is between the school that uses the Ocarino service (the controller) and Red Robot Studios Ltd, the company that provides it (the processor). The agreement begins when the school creates an account and continues until Red Robot Studios has deleted the account’s personal data.

Through the Ocarino service, Red Robot Studios processes staff sign-in email addresses, newsletter settings and content, and browser subscriptions for readers who turn on notifications. Newsletter content may include names and photographs of pupils, staff, and family members.

Processing covers storing, organising, displaying, and deleting this data to operate the service. The data relates to school staff, pupils, and their families.

Red Robot Studios processes personal data only to operate the Ocarino service, including its newsletter pages, link previews, notifications, and calendar dates. Red Robot Studios does not sell the data or use it for advertising, profiling, or training its own models.

Red Robot Studios processes personal data only on the school’s documented instructions. Actions taken through Ocarino and requests sent to Red Robot Studios count as instructions. If the law requires other processing, Red Robot Studios will tell the school before it begins unless the law prohibits notice.

Everyone authorised to access personal data is bound by confidentiality, and Red Robot Studios limits access to what is needed to operate the service. Data is encrypted while it is sent and while it is stored, and Red Robot Studios maintains technical and organisational measures appropriate to the risk, as required by Article 32 of the GDPR.

The school authorises these sub-processors:

• Supabase. Stores staff sign-in and authentication data, newsletter settings and content, uploaded files, reviewed dates, and browser notification subscriptions. Ocarino’s Supabase project is hosted in Ireland on Amazon Web Services. Ireland is the main location for storing and processing this data, although Supabase and its providers may process it elsewhere under the safeguards in the Supabase Data Processing Addendum.
• Resend. Sends staff sign-in emails. It receives the staff member’s email address, the sign-in email and link, and delivery information. Resend’s main processing operations and account data are in the United States, with international transfers covered by the safeguards in its Data Processing Addendum. Its current providers are listed on the Resend sub-processor page.
• Google Cloud. Runs Ocarino in Belgium and processes application requests as needed to provide the service. Google handles this data under its Cloud Data Processing Addendum. Its current providers are listed on the Google Cloud sub-processor page.
• Google Gemini API. Suggests details for dates in the newsletter when the school turns on Smart Assist. Red Robot Studios sends the newsletter name and short excerpts surrounding the dates being reviewed; images and the rest of the newsletter are not sent. Red Robot Studios uses the paid Gemini service, so Google does not use these prompts or responses to improve its products. Google may keep them for up to 55 days to detect abuse and may review material flagged by its safety systems. Newsletter text may be processed outside the UK and EU under the safeguards in the Gemini API terms and abuse-monitoring policy.

Optional notification delivery. When a reader turns on notifications, Ocarino sends an encrypted message through the push service selected by their browser or device. This may be provided by Apple, Google, Microsoft, Mozilla, or Samsung. The provider receives the browser subscription and delivery information, but not the reader’s name or email address, and the message is encrypted so only the reader’s browser can read it. These services are part of the reader’s browser or device rather than sub-processors selected by Red Robot Studios.

Reader-chosen tools. A reader may open a published page with software of their own choosing, such as a browser, calendar app, or AI assistant. These tools act for the reader on content the school has already made public by link, receive nothing beyond the published page and its calendar and date files, and are chosen by the reader rather than sub-processors selected by Red Robot Studios. Ocarino asks search engines not to list published pages and instructs named AI training crawlers not to collect them.

This is the current list, and Red Robot Studios will email account holders before adding a sub-processor. Each sub-processor is bound by a written agreement that imposes data protection obligations equivalent to those in this agreement, and Red Robot Studios remains responsible to the school for its sub-processors’ work.

Red Robot Studios will give the school reasonable assistance with requests to access, correct, restrict, transfer, or erase personal data. It will also help with data protection impact assessments and consultations with regulators where required. Schools can edit, unpublish, and permanently delete issues in Ocarino.

If Red Robot Studios becomes aware of a personal data breach affecting the school’s data, it will tell the school without undue delay, and no later than 48 hours after becoming aware, so the school can meet its own reporting deadlines. The notice will describe the information available at the time and the action being taken.

When the school closes its account, Red Robot Studios will return a copy of its content on request and erase its personal data within 30 days, unless the law requires some data to be kept longer.

On request, Red Robot Studios will provide the information reasonably necessary to show compliance with this agreement and allow reasonable audits or inspections. It will tell the school immediately if an instruction would breach applicable data protection law.

In this agreement, data protection law means the UK GDPR and the Data Protection Act 2018, the EU GDPR, or the equivalent data protection legislation that applies to the school. This agreement is governed by the law of England and Wales.

Signed for Red Robot Studios Ltd by Andrew Gleave, Director. This agreement applies to every school with an Ocarino account. For a counter-signed copy, print and sign this page, then email it to andrew@redrobotstudios.com, and Red Robot Studios will return a signed copy.

Guidance about public pages and photographs is available on the Safeguarding page.