Privacy & Data Governance

Studomia operates governed learning environments.
Data is handled with care, purpose limitation, and institutional alignment.

We distinguish clearly between learning signals, evaluation, and authority.

Our data practices reflect that distinction

Studomia does not treat participant data as a growth asset.

Learning data is contextual evidence generated within structured environments. It exists to support inquiry, reflection, and institutional decision-making — not advertising, profiling, resale, or speculative analytics.

We operate under five principles:

• Purpose limitation
• Data minimization
• Institutional governance alignment
• Participant dignity and contextual integrity
• No secondary commercialization

Learning evidence is preserved before it is interpreted.

Studomia aligns its data governance practices with applicable data protection regulations, including GDPR and relevant national data protection frameworks where engagements occur.

Where applicable, Studomia processes data under one or more of the following lawful bases:

• Contractual necessity (institutional pilot agreements)
• Legitimate interest (structured learning environments)
• Explicit consent (where required)
• Institutional governance agreements

The applicable basis depends on the nature of engagement.

Studomia collects only what is necessary to:

• Facilitate structured learning environments
• Conduct institutional pilots
• Support reflection and synthesis
• Document governance processes

They may include:

• Institutional affiliation and contact details
• Participation artifacts and reflections
• Interaction data within governed environments
• Aggregated learning signals (anonymized where appropriate)

We do not collect unrelated behavioral tracking data.

We do not sell personal information.

Data is used to:

• Facilitate learning experiences
• Support institutional inquiry
• Generate anonymized learning signals
• Inform decision-grade insights within pilots

Data is not used to:

• Declare competency prematurely
• Construct performance rankings
• Create advertising profiles
• Train external commercial AI systems without governance clearance

Learning evidence is interpreted within context and under institutional agreements.

Creative Guild Gatherings and Institutional Pilots operate under defined governance structures.

Before any learning signal is published:

• Identifiable information is removed
• Institutional consent protocols are followed
• Contextual safeguards are applied

Studomia does not publish raw participant data.

Insights are released only when anonymization and governance review standards are met.

Studomia implements reasonable administrative, technical, and organizational safeguards, including:

• Role-based access controls
• Encrypted data transmission
• Restricted internal access
• Governance documentation protocols

Access to identifiable data is limited to authorized personnel under defined responsibilities.

Studomia's public website may use minimal technical cookies necessary for site functionality.

We do not use behavioral advertising trackers or third-party marketing profiling systems.

Where analytics tools are used, they are configured to collect aggregated, non-identifiable usage information.

Data is retained only as long as necessary to:

• Fulfill institutional agreements
• Support structured inquiry
• Meet regulatory obligations
• Preserve governance documentation

Retention periods may vary by engagement type.

Institutions may request review or deletion of data in accordance with contractual and regulatory requirements.

Data retention periods are defined within institutional agreements and internal governance protocols.
Data is not retained indefinitely without purpose.

Where applicable under data protection law, participants may have the right to:

• Access their personal data
• Request correction
• Request deletion
• Restrict processing
• Object to certain processing activities
• Withdraw consent (where consent is the lawful basis)

Requests may be submitted through the contact information below.

When learning environments involve minors, data processing occurs under institutional agreements and applicable safeguarding and child protection standards.

Studomia may process data across jurisdictions in alignment with:

• Institutional agreements
• Applicable data protection regulations
• Appropriate safeguards for cross-border transfers

Where required, contractual protections or equivalent safeguards are applied.

Where AI-assisted tools are used:

• They support reflection and synthesis
• They do not independently evaluate, certify, or declare competency
• They do not replace institutional authority

AI functions as augmentation, not judgment.

Depending on the engagement:

• Studomia may act as a data processor on behalf of participating institutions; or
• Studomia may act as a data controller for governed learning environments it administers.

Role definitions are clarified within institutional agreements.

Studomia Creative Guild operates as the responsible data entity for governed learning environments, unless otherwise defined in institutional agreements. Where required, specific contractual data processing terms apply.