How we handle
your personal data.

A plain-English overview. Each row links to the relevant section for full detail.

Pocket Debate Ltd. ("Pocket Debate", "we", "us", "our") is the data controller responsible for the personal data processed through the Pocket Debate platform. We provide an online oracy platform for competitive debating with AI-powered verdicts and feedback, primarily operating in closed school and institution networks.

Pocket Debate collects the minimum personal data necessary to deliver its educational debate platform. Data is collected directly from users, from schools that administer accounts, and automatically through use of the service.

Personal data is processed only for the purposes described below. We do not sell personal data to third parties and do not use it for advertising or behavioural profiling unrelated to the educational platform.

Every processing activity described in this Policy relies on at least one lawful basis under Article 6 UK/EU GDPR.

Contract (Art. 6(1)(b))

Processing necessary to perform our agreement with the user or school, including account management and platform delivery.

Legitimate interests (Art. 6(1)(f))

Platform security, fraud prevention, aggregated analytics for product improvement, and direct communications with institutional contacts. A Legitimate Interests Assessment is maintained internally.

Legal obligation (Art. 6(1)(c))

Compliance with applicable law, regulatory requirements, and lawful requests from public authorities.

Consent (Art. 6(1)(a))

Where we rely on consent for optional platform features, this is obtained separately and may be withdrawn at any time without detriment to core service access.

Pocket Debate does not sell or rent personal data. We share data with three sub-processors and one encrypted conduit, each subject to a written data processing agreement. LiveKit is documented as an encrypted conduit rather than a sub-processor: because audio is end-to-end encrypted, LiveKit cannot access the data it relays. No personal data is used by any party to train or improve AI models.

The majority of Pocket Debate's processing takes place within the European Union. AWS infrastructure is configured to EU regions (eu-west-3, Paris and eu-central-1, Frankfurt). Anthropic Claude, accessed via AWS Bedrock with an EU inference profile, processes data entirely within those EU regions. No personal data is transmitted to the United States in connection with these services.

There are two international transfers outside the EEA: audio data sent to Groq Inc. for speech-to-text transcription, and live session audio routed via LiveKit Inc. for real-time relay. Both are described in full below. In each case, the transfer is covered by the 2021 EU Standard Contractual Clauses and the UK International Data Transfer Agreement (IDTA), and personal data is not retained by either processor after the relevant operation completes.

The Groq Transfer.

The LiveKit Transfer.

LiveKit provides real-time audio relay for live debate sessions. Audio is routed transiently between participants via LiveKit's US infrastructure. The critical distinction from Groq is encryption architecture: audio is end-to-end encrypted, meaning LiveKit's infrastructure relays encrypted packets without the ability to decrypt or access the audio content. LiveKit is therefore not a processor of personal data in any substantive sense; it is an encrypted conduit. The transfer is nonetheless documented and covered below for completeness and in line with a conservative reading of GDPR Article 46.

Pocket Debate retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, and to comply with applicable legal, regulatory, or contractual obligations. Schools may negotiate shorter retention periods in their Data Processing Agreement.

Every individual whose personal data is processed by Pocket Debate has the rights described below under UK GDPR and EU GDPR. To exercise any right, submit a request to contact@pocketdebate.com. We acknowledge within five working days and respond substantively within 30 calendar days.

You can also submit a request using our Data Subject Rights Request form.

Pocket Debate's Arbiter AI system transcribes spoken debate audio, evaluates argument structure, delivery, and rebuttals, and generates written feedback and a numerical score. These outputs are used for learning, coaching, and competitive ranking within an educational debate context.

Arbiter AI outputs do not produce legal, financial, disciplinary, or otherwise significant real-world effects without human involvement. Where a score contributes to a tournament outcome, the relevant teacher, school administrator, or tournament adjudicator retains the ability to review, query, and override the AI output before any final result is communicated. Human oversight is structurally embedded in the platform design, not offered as an optional add-on, in compliance with Article 22 UK/EU GDPR.

Nature of output

Formative feedback and indicative score for educational use. Not determinative.

Human oversight

Teachers, school staff, and tournament adjudicators can review, query, and override AI outputs before any result is finalised.

Significant effects

None without human involvement. AI outputs do not determine formal qualifications, disciplinary outcomes, or access rights.

Right to human review

Available on request via the school administrator or contact@pocketdebate.com.

AI training

No personal data processed through Pocket Debate is used to train any AI model.

Underlying model

Adjudication is performed via Anthropic Claude accessed through AWS Bedrock EU infrastructure. Processing remains within EU regions at all times.

Pocket Debate does not use cookies, web beacons, pixel tags, device fingerprinting, or any other technology for advertising, analytics, or behavioural tracking. The only cookie Pocket Debate sets is described below.

Session cookie.

To keep a user signed in, Pocket Debate sets a single session cookie in the user's browser once they have authenticated, whether via single sign-on or a password. This cookie contains only a signed session token; it does not carry advertising or tracking identifiers and is not shared with any third party. It is strictly necessary to provide the Service the user has requested (remaining signed in) and, on that basis, does not require cookie consent under the UK/EU ePrivacy rules; no consent banner is presented for this reason. The cookie expires when the session ends and is not used for any purpose beyond authentication.

Identity provider tokens.

Where an Institution uses a single sign-on provider such as Microsoft Entra ID or Google Workspace for Education, that provider's own authentication infrastructure may set session-scoped tokens on the user's device as part of its standard OAuth 2.0 and OpenID Connect authentication flow. These tokens are set and managed entirely by the Institution's identity provider under that provider's own privacy policy (for example, Microsoft's Privacy Statement). They are used solely to maintain the authenticated session and expire on session end. Pocket Debate does not set, read, or control these tokens.

Institutions choose how their users authenticate. Where an Institution operates a supported single sign-on provider, such as Microsoft Entra ID or Google Workspace for Education, Pocket Debate uses that provider for authentication, allowing schools to manage access through their existing identity infrastructure without students or staff creating a separate Pocket Debate password. Smaller debate clubs and Institutions without a supported SSO provider can instead issue their users a Pocket Debate account secured by a password.

When a user authenticates via single sign-on, Pocket Debate receives only the user's name, school email address, and an account identifier from the Institution's identity provider. No passwords, full directory information, or data beyond what is necessary to authenticate the user's account is received or stored by Pocket Debate in this case. Where a password is used instead, Pocket Debate stores only a salted cryptographic hash of the password, generated using bcrypt; the plain-text password itself is never stored, logged, or accessible to Pocket Debate staff. In both cases, this information is used solely for account creation and authentication, not for marketing, profiling, or any other purpose. Where SSO is used, school administrators control access via their identity provider's tenant, and revoking a user's account there automatically prevents Pocket Debate login; multi-factor authentication enforcement is likewise managed at that tenant level. Where a password is used, the Institution's administrator controls the account directly through Pocket Debate. School administrators using Microsoft Entra ID should review Microsoft's Privacy Statement for information on how Microsoft processes account data.

Identity providers

Microsoft Entra ID, Google Workspace for Education, or another single sign-on provider the Institution operates, at the Institution’s choice.

Password storage

Where SSO is not used, passwords are stored only as a salted bcrypt hash. Pocket Debate never stores, logs, or has access to a plain-text password.

Data received (SSO)

Name, school email address, and account identifier only. No passwords, full directory information, or data beyond what is necessary to authenticate the user's account.

MFA / 2FA

For SSO accounts, enforced at the Institution's identity provider tenant level. For password accounts, the Institution is responsible for its own password policy.

Purpose

Account creation and authentication only. Not used for marketing, profiling, or any other purpose.

Access revocation

For SSO accounts, revoking the user's account with the identity provider immediately prevents Pocket Debate login. For password accounts, the Institution's administrator can disable the account directly.

Cookies

Pocket Debate sets one strictly necessary session cookie on login, regardless of authentication method. Where SSO is used, the identity provider may separately set its own session tokens. See Section 10.

Pocket Debate is restricted to users aged 14 and above. This minimum age reflects the requirements of the EU AI Act and applicable data protection law governing the use of AI-powered services with younger children. Schools deploying Pocket Debate are required to confirm that all student users meet this age threshold prior to account creation.

Pocket Debate is committed to the privacy and security of student personal data. The following principles govern all processing of student data through the platform and apply in addition to the general provisions of this Policy.

Pocket Debate applies technical and organisational security measures appropriate to the risk and nature of the data processed. Detailed security documentation is available to institutional partners on request.

Pocket Debate maintains a documented security incident response procedure. Schools and institutional partners are asked to report any suspected security incidents involving Pocket Debate data to contact@pocketdebate.com immediately.

In the event that Pocket Debate Ltd. is involved in a merger, acquisition, financing, reorganisation, sale of assets, or transfer of the business or part thereof, personal data held by Pocket Debate may be transferred to a successor entity as part of that transaction. Any successor entity would be required, as a condition of the transfer, to honour the commitments made in this Privacy Policy.

Where such a transaction would result in a material change to how personal data is processed, including any change to the identity of the data controller, the purposes of processing, or the applicable retention periods: Pocket Debate will notify affected schools and users at least 30 days before the change takes effect. Schools will retain the right to request deletion of their data prior to any such transfer.

This Privacy Policy is reviewed twice annually, in January and July of each year, and updated as required to reflect changes in the platform, processing activities, applicable law, or regulatory guidance. The version number and date on the cover identify the current version.

Material changes, those that substantively alter how we process personal data or affect the rights of data subjects, will be communicated to institutional partners and, where appropriate, to individual users at least 30 days before they take effect. Non-material clarifications such as improved wording, corrected links, or updated sub-processor contact details may take effect immediately upon publication.

Where a school or institutional partner objects to a material change, they should contact us at contact@pocketdebate.com before the change takes effect.

For any question, concern, or request relating to this Privacy Policy or the processing of your personal data, please contact us at contact@pocketdebate.com. We aim to acknowledge all privacy-related correspondence within five working days. For student and parental requests, please contact your school's data protection lead in the first instance; they will liaise with us on your behalf.

Supervisory Authorities.

If you are not satisfied with our response, or believe we are processing your personal data unlawfully, you have the right to lodge a complaint with the relevant supervisory authority.