Closed Beta Privacy Notice

1. Who we are

Chalkmarks is a private teacher memory and professional-identity app. It is currently operated by Caelum Mero, trading as Chalkmarks, in Jersey.

For data protection purposes, Caelum Mero is the controller of personal data processed through Chalkmarks.

Contact: support@chalkmarks.app

2. Who this beta is for

The beta is open worldwide to adults aged 18 or over who are using Chalkmarks in a personal capacity as teachers or education professionals. Participation is not restricted to Jersey.

Chalkmarks is a personal reflection and memory tool. It is not an official school record system and should not be used for safeguarding records, behaviour records, medical or SEND information, disciplinary records, formal pupil assessment records, or other records that a school is required to maintain.

3. Information we process

Depending on how you use Chalkmarks, we may process:

• Account information, including your email address, authentication identifiers and session information.
• Basic profile and onboarding information you choose to provide, such as role, academic-year context and teaching-year start date.
• Content you choose to save, including teaching memories, Thank You memories, text, optional photos, tags, feelings, stars and related timestamps.
• Daily-record information, including Today’s Focus selections and reflections you choose to save.
• Resurfacing information needed for the feature to work, such as whether a memory has been resurfaced, deliberately opened, excluded from resurfacing, and your resurfacing preference.
• Reminder preferences and device-side reminder configuration.
• Technical and security information required to operate and protect the service, such as request identifiers, fixed request route/method/status/timing, authentication lifecycle events, safe error classifications and sync diagnostics. Chalkmarks logging is configured to avoid recording private memory text, request bodies, photo contents or photo paths, email addresses, passwords, authentication tokens, arbitrary query-string content or raw error stacks in its covered application log paths.
• Communications you send to support@chalkmarks.app, including support, privacy and deletion requests.

Optional Chalkmarks product analytics are disabled for the first closed beta. Chalkmarks does not use advertising or marketing tracking within the beta app.

4. Pupil and sensitive information

Chalkmarks is designed for teacher reflection, not for storing identifiable pupil information.

Do not enter pupil names or other information that identifies a pupil. Do not upload photographs containing pupil faces, names, signatures, school records or other identifying details.

In particular, do not use Chalkmarks to record safeguarding information, medical or health information about pupils, SEND information, disciplinary information, allegations, or other sensitive or official pupil records.

Before uploading a photo, check it for names, faces, signatures and other identifying details.

Chalkmarks does not intentionally collect special-category information through its structured fields. Free-text and photo features are controlled by the user, so please do not use them to submit sensitive information that is not appropriate for a personal memory app.

5. Why we use your information and our legal basis

We process account, profile and Chalkmarks content because it is necessary to provide the beta service you have asked to use and to perform the beta agreement between you and Chalkmarks.

We process limited technical, authentication, security and reliability information where necessary for our legitimate interests in keeping Chalkmarks secure, preventing misuse, diagnosing failures, protecting account isolation and operating the beta reliably. We do not use this basis to read or analyse private Chalkmark content for advertising or marketing.

We process information where necessary to respond to privacy, access, correction or deletion requests and to comply with applicable legal obligations.

Support communications are processed so that we can provide support, investigate bugs and respond to requests relating to your account.

Where we rely on consent for a specific optional activity, you may withdraw that consent at any time without affecting processing that was lawful before withdrawal.

6. How we collect information

Most personal data is provided directly by you when you create an account, complete onboarding, save a Chalkmark, add a photo, change a setting or contact support.

Chalkmarks also creates limited functional metadata required to operate features such as authentication, syncing and memory resurfacing.

7. Service providers and sharing

We do not sell your Chalkmarks content or personal information.

We use service providers and platform services to operate and distribute the app. Current providers include:

• Supabase — authentication, database and private object storage for account information, profile/onboarding data, memories and Thank You content, daily records, resurfacing state/preferences and private photos. The Chalkmarks project is configured in eu-central-1 (Frankfurt, Germany), which Supabase identifies as the primary project-data region.
• Render — hosts the Chalkmarks API/runtime. The current Chalkmarks API service is deployed in Render’s Frankfurt region. Normal server-backed profile, memory, daily-record and resurfacing sync requests pass through the Render-hosted API before reaching Supabase. Photo uploads, deletions and signed-photo-URL requests also pass through that API. Render Services, Inc. is US-based and uses subprocessors to provide its services.
• Expo — Chalkmarks uses Expo/React Native technology for app and device functionality. Current capture reminders are scheduled locally on the device; Chalkmarks does not currently use Expo Push Service, collect Expo push tokens or send reminder content through Expo. EAS Update is not currently enabled.
• Apple — iCloud Mail is used to receive and respond to support, privacy and account-related emails sent to support@chalkmarks.app. For the external beta, TestFlight will also process beta-distribution information such as invitation/install status, device/OS information, sessions, crash information and feedback that a tester chooses to submit.

We may also disclose information where required by law, to protect legal rights, or to respond to a valid request from a competent authority.

We do not disclose private Chalkmark content to schools, employers or other teachers as part of the closed beta.

8. International transfers

Some service providers may process personal data outside Jersey or the EEA.

Where an international transfer requires a transfer mechanism, Chalkmarks must use one that is applicable under Jersey data-protection law. Jersey OIC guidance identifies US commercial organisations participating in the EU-U.S. Data Privacy Framework as covered by a partial adequacy finding, and states that transfers covered by adequacy may proceed without the additional safeguards required for non-adequate transfers. Render Services, Inc. is currently listed by the US Department of Commerce as an active participant in the EU-U.S. Data Privacy Framework for non-HR data, including processing customer data as a processor. Chalkmarks therefore relies on that adequacy basis for covered transfers to Render. Render also publishes a Data Processing Addendum incorporating EU Standard Contractual Clauses and a UK Addendum. Where another restricted transfer is not covered by adequacy, Chalkmarks will use the safeguard required under Jersey law, which may include Standard Contractual Clauses together with the Bailiwick of Jersey Addendum and a transfer impact assessment where relevant.

The core Supabase project is configured in eu-central-1 (Frankfurt, Germany). The Chalkmarks API service is deployed in Render’s Frankfurt region. Render Services, Inc. is a US provider and its services and subprocessors may involve processing outside Jersey or the EEA. Apple and Expo may also process service or distribution data outside Jersey depending on the services used.

9. How long we keep information

We keep your account and Chalkmarks data while your beta account remains active and while it is needed to provide the service.

If the beta ends, we will give reasonable notice where practical and explain what will happen to existing accounts and data.

The in-app Permanently delete your archive function remains an archive-only action. It removes Chalkmarks archive content within its stated scope, associated targeted photos and local Chalkmarks state, but it does not delete the underlying authentication identity or email login.

Chalkmarks also provides a separate in-app Delete account action for full account deletion. Once an account-deletion request is accepted, Chalkmarks blocks further account writes and is designed to remove that account’s Chalkmarks database data, private Storage objects/photos and authentication identity, with retry handling if a deletion step is interrupted. You may also contact support@chalkmarks.app about deletion or if the in-app process does not complete as expected.

Technical logs, security records and support communications are kept only for the operational, security, legal or support purpose for which they are needed and are also subject to the retention schedules of the relevant service provider. These records are separate from your Chalkmarks archive and may persist for a short period after account deletion. Where an exact period is not fixed, the criterion is whether the information is still needed for that purpose or remains within the provider’s normal retention period.

Downloaded exports are outside Chalkmarks’ control once you save them to your own device or another service.

10. Exports

Chalkmarks currently provides an archive export in structured JSON format.

The export may include memory data and references or URIs associated with photos, but it does not currently package copies of the original photo files themselves. Do not rely on the export as a complete photo backup.

11. Security

Chalkmarks uses account authentication, private storage and same-user access controls intended to prevent one user from reading, editing or deleting another user’s private Chalkmarks.

The beta has been tested for account isolation and common data-integrity failures, but it remains beta software and may contain defects. For the first closed beta, Chalkmarks does not currently maintain an independent off-provider backup of the production database or private photo files, so recovery from accidental loss cannot be guaranteed. Do not use Chalkmarks as the sole copy of information that is legally, professionally or operationally important.

12. Notifications

Capture reminders are optional and teacher-controlled. Current capture-reminder scheduling is device-local. Chalkmarks does not currently use Expo Push Service or an Apple Push Notification service server flow for capture reminders.

Chalkmarks does not require daily use and does not use streaks or guilt-based reminders.

13. Automated decision-making

Chalkmarks does not use automated decision-making or profiling that produces legal or similarly significant effects about you.

The resurfacing feature uses product logic to decide which of your own saved memories to show back to you. This is part of the app experience and is not used to make employment, eligibility, disciplinary or other significant decisions about you.

14. Your rights

Under Jersey data-protection law, rights may include the right to:

• be informed about how your personal data is used;
• request access to your personal data;
• ask for inaccurate data to be corrected;
• request erasure of personal data where the legal conditions apply;
• request restriction of processing where applicable;
• object to certain processing where applicable; and
• receive certain data in a portable format where the legal conditions apply.

To exercise a right or ask a privacy question, contact support@chalkmarks.app.

We may ask for information reasonably necessary to confirm your identity before acting on a request.

15. Complaints

If you have concerns about how Chalkmarks handles personal data, please contact support@chalkmarks.app first so we can try to resolve the issue.

You also have the right to complain to the Jersey Office of the Information Commissioner (JOIC):

Jersey Office of the Information Commissioner
2nd Floor
5 Castle Street
St Helier
Jersey
JE2 3BT
Email: enquiries@jerseyoic.org

16. Changes to this notice

We may update this notice as the beta develops or if our data handling changes. If a change is material, we will make the updated notice available and, where appropriate, draw it to testers’ attention before the new processing begins.

Contact: support@chalkmarks.app

This website

This website is hosted with ChatGPT Sites. The beta waitlist form records the details described below. No analytics have been added. Email links open your own email application.

Beta waitlist registrations

When you join the website waitlist, Chalkmarks collects your first name, last name if provided, email address, country or territory, iPhone access, and teaching phase if you choose to provide it. We also record your confirmation that you are a teacher aged 18 or over, your agreement to beta contact, and the time you register.

We use these details to manage beta registrations and contact you about beta access and feedback. After successful signup, iPhone users receive a TestFlight invitation link on the website. They are not published, sold or used to add you to a general marketing mailing list. Registration does not guarantee access; TestFlight confirms whether places are available. Teachers worldwide may register for the current beta; participation is not restricted to Jersey.

We keep waitlist details while they are needed to manage beta recruitment and follow-up, or until you ask us to remove your registration. Registrations are stored in the website’s hosted database through OpenAI Sites and Cloudflare. Access is restricted to the site owner and authorised site editors. You may withdraw your registration or ask for your details to be corrected or deleted by emailing support@chalkmarks.app. Please do not submit school or pupil information.