UAE Data Protection
Last updated: 30 September 2026
Processing and retention, policy of 1 October 2026
Guide drafting and content review use Luna as the primary model, with Gemini as the configured backup, through OpenRouter. Safeguarding uses Llama Guard and, when needed, a separate Gemini curriculum reviewer. Model developers and the companies operating inference endpoints are not necessarily the same.
Our OpenRouter account has zero data retention (ZDR) enabled, and requests also require ZDR inference endpoints. This applies to provider processing of prompts and outputs, including retries and fallback. It does not delete your saved AILitKit guides, account records or necessary service metadata. OpenRouter permits temporary in-memory prompt caching under its ZDR policy.
Before new generation, automated safeguarding checks read the subject, stage, year group and topic, plus up to the first 1,000 characters each of the teacher description and extracted upload text. Llama Guard gives a first verdict; a Gemini reviewer runs if that verdict is unsafe, unavailable or unreadable. An additional direct OpenAI moderation check runs when configured, under its separate API terms. If no usable safeguarding verdict is available, generation pauses with a retry message. A usable unsafe verdict is preserved if its reviewer fails; hard-block categories cannot be cleared by that reviewer.
Before saving a newly generated guide, automated checks review lesson fit, accuracy, activity logic, resources, pupil language and AI literacy. Up to four batches inspect the draft against the teacher brief; one correction cycle is allowed, followed by another review of all batches. Failed or unavailable review prevents the new guide from being saved. Saved review evidence and resolved findings may quote the brief or draft. These checks can miss errors and are not human approval or a dedicated final-output safety classifier. Existing guides are not retrospectively checked; eligible saved guides may be reused.
Pupil-facing language is targeted using the year group or key stage supplied by the teacher. This is a class-level assumption, not an individual reading-age assessment. Teachers must adapt wording and resources for their actual readers, including SEND and EAL needs, and check third-party tools, links and safeguarding before classroom use.
While a guide is being built, its job record holds the request needed for processing and retries. On completion, failure or expiry, that record loses its input payload and duplicate output. Identifiers, scope, status, timings, usage and support diagnostics remain temporarily: completed jobs are eligible for deletion after 24 hours, and failed or expired jobs after seven days, at the next successful cleanup. The saved guide, its input description and review evidence follow the guide retention period.
After successful generation, cleanup deletes the original uploaded file and clears the extracted text from the upload record, keeping filename, type and date. Unused uploads and failed cleanup are eligible for the scheduled sweep once the upload is over one hour old. The sweep runs every 15 minutes; deletion can take longer if a cleanup attempt fails. Relevant source-derived material can remain in the saved guide and its review evidence.
Guide generation does not grade pupils, decide admissions or progression, or assess individual learners. Automated service checks do decide whether a request can proceed and whether a draft passes review. A second AI model is not human intervention. You can ask a person to review a refusal or flag by contacting hello@ailitkit.com; we aim to respond within five working days. A content flag is not a finding of misconduct by a teacher.
Do not enter identifiable pupil information, assessment records, safeguarding records, EHCP/SEN documents or staff personal data. AILitKit needs curriculum content only. Warnings and input cleaning do not guarantee anonymisation: information entered accidentally can still be processed and appear in a saved guide or audit evidence. Contact hello@ailitkit.com promptly if this happens.
Safeguarding audit retains a classifier explanation that may refer to screened content. Allowed decisions keep no input snapshot; flagged decisions also keep the topic and a short description excerpt. Saved guide review evidence follows the guide retention period, including its 30-day undo window. Hosting logs and backups have separate service schedules. The school reviewer should obtain the current processor, transfer and retention evidence and record their own risk decision.
Key position
AILitKit is for adult teachers planning lessons. Student accounts and education records are not required. Teachers must remove identifying information before submission; accidental inclusion can still lead to processing. Schools should assess their own use and applicable obligations.
UAE PDPL compliance
Schools should confirm the applicable legal basis, processing agreement and local requirements with their data-protection contact. The processing description above covers accounts, guide creation and review, service administration and safeguarding. See the Privacy Policy for rights, communication purposes and retention.
Cross-border data transfers
AILitKit uses service providers located outside the UAE. The school should assess applicable transfer requirements, including the federal PDPL or relevant free-zone regime. Current service details:
| Service | Purpose | Data | Location |
|---|---|---|---|
| OpenRouter | Luna drafting and content review; Gemini backup; Llama Guard and conditional Gemini safeguarding | Teacher brief, extracted source, draft and review context (ZDR inference routing) | Depends on the inference operator; processing can occur outside the UK/EEA |
| OpenAI (direct, when configured) | Additional moderation | Safeguarding input sample; separate OpenAI API terms | Not stated in our privacy policy; ask us for the current transfer evidence |
| Supabase | Database, authentication, file storage | Account data, guides, safety and audit logs | EU (eu-west-1) |
| Stripe | Payment processing | Email, payment details, subscription state | Not stated in our privacy policy; ask us for the current transfer evidence |
| Resend | Transactional and lifecycle email; delivery-status webhooks (bounce, complaint) | Email address, display name | Not stated in our privacy policy; ask us for the current transfer evidence |
| Vercel | Application hosting, scheduled jobs | Application requests and operational diagnostics | Hosting includes processing in the US |
| Upstash QStash | Guide generation scheduling | Job identifier; retry and dead-letter retention follow account settings | Depends on the service configuration |
Obtain the current processor agreements, actual destinations and applicable transfer safeguards during procurement. An EU database location does not mean all processing stays in the EU. ZDR restricts AI-provider retention and is not a transfer mechanism; it does not imply that every copy is held only in the primary database.
Supervisory authority
The UAE Data Office is the supervisory authority for personal data protection under the PDPL. If you have concerns about how AILitKit handles your data, you may contact the UAE Data Office or reach us directly.
Your rights under PDPL
- Right of access: You can request a copy of your personal data. Use the Export Data button in your account settings.
- Right to rectification: You can update your personal data at any time from account settings.
- Right to erasure: You can delete your account from account settings. This removes account-linked records from active storage. Deleted guides have a 30-day undo window and are then purged. Backups follow their own schedule; this is not a promise of immediate erasure from every backup.
- Right to restrict processing: Contact us to restrict processing of your data.
- Right to object: You may object to processing based on legitimate interest.
MoE and KHDA alignment
AILitKit supports UAE schools in meeting the Ministry of Education's AI literacy mandates and KHDA's AI Literacy Framework for Dubai private schools. The platform generates guides mapped to UAE-specific frameworks, helping teachers embed AI literacy into their existing subject teaching. See our Safeguarding & Responsible Use page for details on framework alignment.
Data Protection Assessment
If your school requires a data protection impact assessment under the PDPL, a pre-filled assessment template is available on our data protection page for schools, ready to print or save as PDF. No account needed.
Contact
For data protection enquiries, contact hello@ailitkit.com. Processing locations and retention periods are set out on Data protection for schools.