Legal information
1. Service provider and data controller
The ScuolaAI service (www.scuolaai.it) is provided by:
FreeFuture LDAServiços de Consultoria e Investimentos Unipessoal
Rua de Carreira 115/117, Funchal, 9000-042, Portugal
NIPC:
516654527Italian VAT no.:
00415249994Tax address (Article 35): Studio Cerone Granieri, Via Palmiro Togliatti 1964, 00155 Roma
Email: max@freefuture.eu
Corporate website: www.freefuture.eu
Controller of personal data under the GDPR.
2. Scope of the service
ScuolaAI is an AI-native learning platform designed for a blended classroom and digital model, focused on informed, ethical, and practical use of Artificial Intelligence. Its operational digital core includes:
- Five levels, L0–L4: the L0–L3 core program followed by the ongoing L4 Frontier community of practice, with Mind and Hands tracks
- Interaction with a personalized AI Tutor based on third-party models (Anthropic, OpenAI)
- A digital Atelier workspace for creating work with authorship tracking
- A Notebook for homework (a separate section of the system)
- Issuance of competency certificates that can be verified online
- A proposed in-person format of three days a week; location, schedule, and procedures are validated and communicated for each cohort before it begins
3. Personal data processing (GDPR)
Categories of data collected
- Identification data: first name, last name, email address, username
- Profile data: bio, voice statement, campus, assigned supervisor
- Learning data: lesson progress, P6 reflections, open questions, conversations with the AI Tutor
- Work created: files written in the Atelier with version history and recorded source (manual, pasted, AI-suggested)
- Submitted assignments with AI assessment and, where applicable, human review
- Learning Compass data: self-assessments, tasks, AI interview, scores, suggested level, and review requests
- Learning-related inferences: observed competency levels, feedback, possible shortcut flags, and rubric results
- Administrative and financial data: tuition, bank transfer declarations and manual confirmations, scholarships, certificates and their public UUIDs; integrated payment-provider checkout is not operational
- RFID badge identifier, if assigned, used for quick account sign-in rather than physical access control or attendance tracking
- Minimal technical data (IP address, access logs) processed for security
Purposes of processing
- Accounts, Tutor, Learning Compass, lessons, assignments, progression, and certificates: performance of the contract and pre-contractual measures
- Security, audits, abuse prevention, and service continuity: the controller’s legitimate interest, balanced against users’ rights
- Accounting, payments, and defense of rights: legal obligations and, where necessary, legitimate interest
- Optional reuse of student work and promotion with attribution: specific consent, revocable without affecting participation in the course
Retention
Profiles, conversations, work, progress, Learning Compass records, and assignments are retained during the learning relationship and, absent disputes, deleted when the account is deleted. Security data is normally retained for 90 days. Records of consent are retained for 5 years after the latest choice. Accounting records and payments are retained for the period required by applicable law, ordinarily up to 10 years, with identity records separated from the deleted account. Certificates remain verifiable through their UUID and competency records; after account deletion they display neither names nor initials. The policy provides for rotating backups limited to the two most recent copies; configuration, encryption, and restoration testing must be verified before scaling and are not certified by this page.
Transfers to third countries
Interaction with the Tutor and semantic assessments involve sending strictly necessary prompts, conversations, and evidence to OpenAI and Anthropic as data processors for their API services. OpenAI is called with application-state storage disabled (store=false); both providers may retain technical or security data under their respective terms, normally for up to 30 days for standard API calls. Any transfers outside the EEA require data processing agreements, appropriate safeguards, and a documented transfer assessment. Review of DPAs, Standard Contractual Clauses, account configuration, and applicable measures must be completed and documented before scaling.
4. Your data rights
Under Articles 15–22 of the GDPR, you have the right to:
- Access your personal data (Article 15)
- Request correction (Article 16)
- Request deletion (right to be forgotten, Article 17)
- Restrict processing (Article 18)
- Receive your data in a structured, readable format (portability, Article 20)
- Object to processing (Article 21)
- Not be subject to automated decisions with significant effects (Article 22)
ScuolaAI provides two operational tools in the student profile:
- Data export: A structured ZIP containing your profile, conversations, workspaces and versions, progress and assessments, portfolio, Learning Compass and appeals, assignments, projects, consent records, finances, certificates, and the associated technical model registry.
- Account deletion: deletion of learning data and account identity. Any retained audit, accounting, and certificate records no longer link to the user; IP addresses and user agents are removed from consent records.
To exercise other rights or submit a complaint, contact max@freefuture.eu.
5. Cookies and tracking
ScuolaAI uses only technical cookies needed to operate the service (authentication, session, CSRF, and website language). There are no profiling cookies or tracking for marketing purposes.
6. Use of AI systems (AI Act)
ScuolaAI uses third-party Artificial Intelligence systems (Anthropic Claude, OpenAI GPT) as an integral part of its learning offering. To apply the principles of Regulation (EU) 2024/1689 (the AI Act), while classification and compliance documentation remain under validation, ScuolaAI currently applies the following controls:
- Students are always informed when they interact with an AI system (provider labels on messages)
- AI assessments evaluate submitted evidence and may allow progression or require another attempt; students may challenge an outcome, and the supervisor’s reasoned decision is binding
- The Learning Compass combines self-assessment, AI tasks, and an interview: the least developed dimension and the average determine the L0–L3 level and any exemptions. Before the level and tuition take effect, students may request human review, which pauses all consequences until a decision is reached
- Tutor prompts are versioned in the code; a governed registry of models, prompts, and calls is required before scaling
- Proposed curriculum updates include a review against the pillars and a human decision; major revisions remain under validation until the stable version seen by each student is guaranteed
- Authorship shown in the Atelier is an application-level indication based on declared and recorded actions, not forensic proof of a text’s origin
7. Terms of use
Enrollment in ScuolaAI implies acceptance of these conditions. Users agree to:
- Use their account personally and not transfer it to third parties
- Respect the confidentiality of learning materials
- Not use the platform for unlawful purposes or to produce harmful content
- Honestly declare their own contribution to submitted work
- Respect other community members in group projects and community channels
The provider reserves the right to suspend or terminate an account for serious or repeated violations, following written notice of the violation.
8. Minors
The service is not intended for children under 14. Students under 18 require consent from a parent or a person with parental responsibility. The school does not provide automated parent notifications: responsibility for the learning journey remains with the student.
9. Intellectual property
9.1 Learning materials
The school’s learning content (curriculum, published materials, Tutor system prompts, and software infrastructure) belongs to FreeFuture LDA and is protected by copyright law. Students receive a personal, nontransferable right of use for the duration of their enrollment.
9.2 Student work
Everything a student creates in the Atelier (text, code, reflections, projects) belongs to that student — a founding principle of the school (pillar P6: “thought has an author”). Moral rights in the work (authorship and integrity) are inalienable and always remain with the student, including when promotional use is authorized.
Students grant ScuolaAI a limited, free, revocable license for the technical purposes of assessment, educational supervision, and service improvement. Deleting an account revokes this license (competency certificates already issued remain valid and verifiable; see section 11).
9.3 Granular consent for promotional and educational use
On their profile page, students can grant or withdraw three specific permissions at any time:
- Anonymous case studies (OFF by default): ScuolaAI may show work with identifying information removed to other students as educational examples.
- Learning library (OFF by default): Anonymous inclusion in materials reused with future classes.
- Named attribution in promotional materials (OFF by default; explicit opt-in required under the GDPR): ScuolaAI may feature work with the student’s name in promotional materials (website, social media, events, pitches).
Every consent change is timestamped in a chronological application log (GDPR Article 7(1)). Infrastructure protections against tampering and WORM storage are not yet declared operational.
9.4 Aggregated and anonymized data
Students grant ScuolaAI the perpetual and irrevocable right to use their participation data in aggregated and anonymized form for educational research, demonstrations of learning impact, and institutional reporting (for example, “73% of L2 law students completed their thesis in 2026”). Identifiable data is never used without the explicit consent described in section 9.3.
9.5 Group projects
Group projects are jointly owned by all participating members. No individual member may claim them as their sole work, transfer them to third parties, or modify them by removing others’ contributions.
An individual presentation of a group project (portfolio, export, external sharing) always names all coauthors and the specific contribution each declared at submission.
Any reuse of a group project by ScuolaAI requires the explicit consent of all members for the specific purpose: an anonymous case study, learning library, or named promotion. Withdrawal by even one member disables that reuse for the entire project.
10. Governing law and jurisdiction
This agreement is governed by Portuguese law (the controller’s registered location) and, for mandatory Italian provisions concerning consumers residing in Italy, by Italian law. Disputes fall within the jurisdiction of the consumer’s court or, where this does not apply, the court of Funchal (Portugal).
11. Contact
FreeFuture LDA — ScuolaAIEmail: max@freefuture.eu
Certified email (PEC) / institutional contacts: see www.freefuture.eu
To exercise your GDPR rights, write to the email address above with the subject “GDPR Request”.