Data Terms.

These Data Terms apply to personal workspaces on the Free plan and form part of our Terms of Service (clause 5.8) between Difinity Pty Ltd (ABN 82 686 692 759), the operator of Loam (Loam, we, us), and the individual educator who holds the workspace (you). Institutions on a School plan get our full Data Processing Agreement instead; if your school later takes over your records under a School plan, its DPA governs them from that point. These terms are deliberately short: they are the same commitments we make to institutions, in the form an individual can actually read.

You decide which of your classes and assignments use Loam. We process the information in your workspace (including your students' work and its evidence records) only to provide, secure and support the Service, as configured by you in the product, and on no independent purpose of our own. Student work and evidence records in your workspace are academic records of your students and their school, held by you as their teacher; our Privacy Policy (section 5) and the Terms of Service (clause 5) describe that framing, including what happens if your school asks for its records.

Where available, you may sign in using Google or Microsoft as an identity provider instead of a Loam password; we do not send your students' work, evidence records or submissions to an identity provider (see the Privacy Policy, section 3).

We will not sell the personal information in your workspace. We will not use it for advertising. We will not use student work or evidence records to train artificial-intelligence or machine-learning models. We will not use keystroke-timing or cadence data to identify or verify the identity of any individual. The only thing we do with data beyond running the Service is aggregated, de-identified usage statistics that identify no individual, workspace or document content.

Your workspace, including student work, evidence records and encrypted backups, is hosted with Amazon Web Services in the data centre for the region you select when you sign up: AWS Asia-Pacific (Sydney) for Australia, AWS Europe (Frankfurt) for Europe, or AWS US East (N. Virginia) for the United States. Your workspace, including backups, remains in that region. Difinity's operations personnel are in Australia. In the Australian operations system they can see only opaque Loam identifiers for the student, teacher, school and support request, together with the name, work email address and support messages of a teacher or school administrator who contacts us. They cannot see or receive a student's name, email address, date of birth, writing, replay, evidence record or other directly identifying student details or student content. Student content and direct student identifiers remain in the institution's selected region.

If you are outside the region you chose, using Loam still means your information, and your students' information, is stored in that region, not necessarily where you are. From your country's perspective this may be an international transfer. For educators in the EU or UK: if your workspace is in the Europe region, there is no storage transfer to Australia, but the Australian access described above is a transfer, and Australia does not hold an adequacy decision. These Data Terms do not themselves incorporate the EU Standard Contractual Clauses or the UK International Data Transfer Addendum. If your use requires either instrument, contact hello@loam.ink before using the Service so the applicable terms can be agreed in writing.

The Free plan involves no billing, so no payment provider ever touches your data: no card, no Stripe, no billing records about you or your students.

We protect your workspace with the same measures institutions get: end-to-end TLS for data in transit across all regions, and encryption at rest, including backups; tamper-evident evidence storage (SHA-256 hash-chained records with server countersignatures, so alteration is detectable, including by us); passwords stored only as salted argon2 hashes; secure, httpOnly session cookies; per-workspace isolation with tenant-scoped access controls; logged production access, with further work scheduled to narrow deploy and operational access; encrypted nightly backups retained for 30 days and encrypted monthly backups retained for 1 year in each region; and a documented data-breach response plan.

We will notify you without undue delay after becoming aware of a data breach affecting your workspace, describing, to the extent known, what happened, what information and how many people are affected, the likely consequences, and what we are doing about it. Where the breach is likely to result in serious harm we also comply with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth). Because the records concern your students, we will work with you (and, where appropriate, their school) so families hear it accurately and quickly.

• Export is always free. You can export student work and evidence records (as portable evidence bundles that can be verified independently of us) at any time, including before and during any retention deletion and after you stop using the Service (per the Terms of Service, clause 5.3).
• Retention. The Free plan's retention schedule is in the Privacy Policy (section 11): the replayable evidence record for each submission is kept for 12 months from submission, with staged notices at 60, 30 and 7 days before anything is deleted, a free one-click export in every notice, and a dispute hold for records involved in an academic-integrity, appeal or legal process.
• Deletion. You can delete individual records or your whole workspace. Workspace deletion is confirmed, has a 30-day recovery window, and then removes your data from live systems, with encrypted backup copies remaining until they age out on our rolling backup schedule. In all regions, nightly backups are retained for 30 days and monthly backups are retained for 1 year, unless the law requires longer retention. Deletion of tamper-evident evidence records is permanent.

Changes to these Data Terms are prospective. We will give you reasonable advance notice of material changes by email, and we will never weaken the commitments in section 2 without your clear, advance, opt-in agreement.