Privacy Policy
Effective May 27, 2026
1. Who we are
Sina is operated by Clustr ("we", "us"). This policy describes what personal data we collect when you use Sina, why we collect it, and what your rights are.
2. Data we collect
- Account data: name, work email, organization, role, and platform track.
- Learning data: assessment responses, lesson and lab progress, XP, streaks, and Sina Score.
- Prompt and activity inputs: text you submit into AI activities and exercises.
- Usage data: session timestamps, pages visited, device and browser metadata.
- Support data: messages you send to us.
3. Why we use it
- Provide, secure, and improve the learning experience;
- Personalize the program and surface relevant practice;
- Report progress to your organization administrators (aggregated and individual);
- Communicate with you about the Service;
- Comply with legal obligations.
4. Legal bases (GDPR)
Where GDPR applies, we process personal data under one or more of these legal bases: performance of a contract, legitimate interests (improving and securing the Service), consent (where required), and compliance with legal obligations.
5. Sharing
We share personal data only with:
- Your organization's administrators, where applicable;
- Sub-processors that help us run the Service (hosting, analytics, AI model providers) under written data-protection terms;
- Authorities, when legally required.
We do not sell personal data.
6. AI providers
Prompts you submit may be processed by third-party AI providers (such as Microsoft, OpenAI, Anthropic, or Google) under enterprise agreements that prohibit using your content to train their public models. Do not submit confidential or regulated information into AI activities unless your organization has authorized it.
7. International transfers
Personal data may be processed outside your country. Where required, we use Standard Contractual Clauses or equivalent safeguards.
8. Retention
We retain learning data for the duration of your organization's engagement with Sina and for a reasonable period afterward for audit and reporting. Demo accounts are retained only as long as needed to provide the demo.
9. Your rights
Depending on your jurisdiction, you may have rights to access, correct, export, restrict, or delete your personal data, and to object to certain processing. To exercise these rights, contact us using the address below. If your account is managed by an organization, please direct requests to that organization first.
10. Security
We use encryption in transit, access controls, and routine security reviews to protect personal data. No system is perfectly secure; please notify us promptly of any suspected security incident.
11. Children
Sina is not directed to children under 16 and we do not knowingly collect their personal data.
12. Changes
We may update this policy. Material changes will be communicated through the Service or by email.
13. Contact
Privacy questions: [email protected].