Privacy Policy

The Masary Programme, an AI-enabled career guidance platform for students in Grades 8–12 is committed to protecting the privacy of every student, parent, counsellor, and visitor who uses Masary. This policy explains what personal data we collect, why we collect it, how we use and protect it, who we share it with, and the rights you have over your data. Where this policy refers to “Masary” it includes the website, the learning platform, the AI guidance features, and related communications.

1. Who is responsible for your data

Data Controller: MindBase Education

Data Protection Office Contact: hello@masaryhub.com. All data-protection questions, requests, and complaints can be sent to this email address.

2. Scope of this policy

This policy covers personal data we process about three main groups:

  • Students (Grades 8–12), who use the Masary platform, complete assessments, and progress through the six-layer journey;

  • School staff, including counsellors, career-guidance teachers, and school administrators who use the counsellor dashboard;

  • Parents and guardians, who provide consent, receive updates, and use the parent portal; and

  • Website visitors, including general users, partners, and media visitors to masaryhub.com.

3. What personal data we collect

3.1 From students

Category Examples
Identity & enrolment Name, grade/year, school, gender, year of birth or age band, student identifier issued by the school or platform
Account & access Username, encrypted password, login activity, device and session information
Assessment & profile data Responses to the 4-D Discovery Assessment, CDSE-SF responses and scores, career archetype, RIASEC interest profile, pathway shortlist and fit scores
Learning & progress data Module completion, quiz and assessment scores, layer progress, mini-project submissions, badges earned, time-on-task and engagement events
AI interactions Messages exchanged with the Masary AI modules and the guidance, drafts, and feedback those generate
Action-plan data University shortlists, application timelines, subject/stream choices, and target test scores recorded

3.2 From school staff

Name, work email, role, school, dashboard login activity, action-plan reviews, counsellor–student session notes, and reporting interactions.

3.3 From parents and guardians

Name, relationship to the student, contact details (email and/or mobile number for WhatsApp and broadcast communications), consent records, and parent-portal activity.

3.4 From website visitors

Information submitted through forms (for example “Request a demo” or enquiry forms), plus technical data collected automatically such as IP address, browser type, device type, pages viewed, and cookie identifiers. See the Cookie section below.

4. How we collect personal data

  • Directly from you when you register, complete assessments, interact with the AI personas, submit work, or contact us;

  • From your school, which provides enrolment and roster information under its agreement with MindBase;

  • Automatically, through the platform and website as you use them (activity logs, cookies, and analytics); and

  • From parents/guardians, when they provide consent or contact details.

5. Why we use your data and our legal basis

We process personal data only where we have a lawful basis to do so under the UAE Personal Data Protection Law and, where applicable, the GDPR. Our purposes and bases include:
Purpose Legal basis
Provide the Masary platform and deliver career guidance Performance of our agreement with the school; consent of the student/guardian
Generate assessment results, pathway matches, and AI guidance Consent; legitimate interest in delivering the service
Measure programme impact (e.g. CDSE-SF change, completion, longitudinal tracking) Legitimate interest; consent for any optional follow-up
Report aggregated, de-identified outcomes to schools and stakeholders Legitimate interest; contractual obligation to partners
Communicate with parents and schools (progress updates, events) Consent; performance of agreement
Secure the platform and prevent misuse Legitimate interest; legal obligation

6. Children’s data and parental consent

Masary is designed for students in Grades 8–12, many of whom are minors. We take particular care with their data. Where required by law, a parent or guardian must provide verifiable consent before a minor’s personal data is processed, and consent is obtained through the school and/or the parent portal as part of onboarding.

  • We collect only the data necessary to deliver guidance and measure impact, we do not sell children’s data or use it for behavioural advertising.

  • Students always operate within a counsellor-supervised environment; school counsellors have oversight of student journeys through the dashboard.

  • The Masary AI modules operate within strict policy boundaries. They do not write students’ essays for them, provide exam answers, guarantee admissions outcomes, or handle crisis or safeguarding situations, any such language is escalated to a human counsellor.

  • Parents and guardians may review their child’s data, withdraw consent, or request deletion at any time by contacting the school counsellor or our DPO.

7. Automated processing and AI

Masary uses automated processing to generate assessment scores, pathway match suggestions, and AI guidance. These outputs are decision-support tools, not binding decisions: they are designed to inform conversations between a student, their counsellor, and their family. No student is subject to a solely automated decision that produces a legal or similarly significant effect without human counsellor involvement. Students and guardians may ask a counsellor to review or explain any AI-generated guidance.

8. Who we share data with (third-party processors)

We share personal data only with parties who help us run Masary, under written agreements that require them to protect it and use it only on our instructions.

We do not sell personal data. We may disclose data where required by law, regulation, or valid legal process in the UAE.

9. Where your data is stored (data residency)

Masary data is hosted within the United Arab Emirates. Personal data is stored on infrastructure located in the UAE in line with national data-residency expectations. Where any processing or sub-processing would occur outside the UAE, we will only permit it where the law allows and where appropriate safeguards (such as contractual protections and an adequate level of protection) are in place.

10. How long we keep your data

We retain personal data only for as long as needed for the purposes described in this policy, for the duration of the school’s participation in Masary, and for any period required by law. After that, data is securely deleted or irreversibly anonymised. Longitudinal tracking data is held in de-identified form where possible. Specific retention periods are set out in our internal retention schedule and can be requested from the DPO.

11. How we protect your data

We apply technical and organisational measures appropriate to the sensitivity of the data, including encryption in transit, access controls and role-based permissions, logging, and staff confidentiality obligations. We require the same standards of our processors. No system is perfectly secure, but we work to reduce risk and to respond quickly to any incident, including notifying affected individuals and authorities where the law requires.

12. Your rights

Subject to the conditions in the UAE PDPL (and the GDPR where it applies), you have the right to:
  • Access the personal data we hold about you;

  • Rectify data that is inaccurate or incomplete;

  • Erase your data (“right to be forgotten”) where there is no overriding legal reason to keep it;

  • Restrict or object to certain processing;

  • Withdraw consent at any time, without affecting processing already carried out;

  • Data portability receive your data in a structured, commonly used format; and

  • Complain to the relevant UAE data-protection authority.

For students who are minors, these rights can be exercised by a parent or guardian. To make a request, contact our DPO at hello@masaryhub.com. We will respond within the timeframe required by law and may need to verify your identity first.

13. International (GDPR) users

If you access Masary from the European Economic Area or the United Kingdom, we align our handling of your data with the GDPR. This means we rely on a valid legal basis, honour the rights listed above, limit international transfers, and provide a route to complain to your local supervisory authority. The UAE remains the primary place of processing.

14. Cookies and similar technologies

masaryhub.com uses cookies and similar technologies to make the site work, remember your preferences (including language), and understand how the site is used so we can improve it. We group cookies as:

  • Strictly necessary — required for the site and platform to function (always on);

  • Preference — remember choices such as Arabic/English language;

  • Analytics — help us measure and improve performance; and

  • Marketing/retargeting — used only with your consent to support awareness campaigns.

On your first visit you will see a cookie banner that lets you accept or reject non-essential cookies. You can change your choices at any time through the cookie-settings link in the website footer, or by adjusting your browser settings.

15. Changes to this policy

We may update this policy from time to time. When we make material changes we will update the “last updated” date and, where appropriate, notify schools and parents. Continued use of Masary after an update means you accept the revised policy.

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