Privacy Policy

We believe that privacy is important, and we take your privacy seriously. As used in this Privacy Policy, “FourtyFive” or “we” means FourtyFive For Online Selling, a sole establishment licensed by the Dubai Department of Economy and Tourism (Trade License 1643126), with its registered address at Office, Cayan Tower, New Dubai, Dubai, United Arab Emirates.

We are committed to protecting your privacy. This Privacy Policy outlines how we collect, use, and protect personal data obtained through our platforms (including fourtyfive.org and app.fourtyfive.org), our services, or otherwise, and how you can exercise any rights available to you under applicable data privacy legislation, including the General Data Protection Regulation (GDPR), the UK Data Protection Act 2018 (UK GDPR), and the UAE Federal Decree-Law No. 45 of 2021 regarding the Protection of Personal Data (UAE PDPL).

FourtyFive acts as the data controller in relation to the processing of your personal data in accordance with this Privacy Policy.

Our platform uses Large Language Models (LLMs) to provide automated marking and instant feedback on your academic inputs.

Data privacy with LLMs. To generate feedback, we share the specific question, your submitted answer and any related prompt with our enterprise LLM API providers. These providers act as our sub-processors, process that data only on our documented instructions, and are contractually prohibited from using your personal data or study inputs to train their underlying base models.

Automated decision making. We use AI to mark practice questions, estimate grade boundaries and build your mastery profile. These outputs exist for revision and educational feedback only. They are not official marks and they are not academic decisions. We do not use your personal data to make solely automated decisions that produce legal effects, or similarly significant effects, for you. Our Terms of Service set out the limits of AI output in more detail.

Telling us when marking is wrong. You can flag any marked answer using the feedback control on that answer, and we review what you send us.

We do not sell your personal data. We may share your data with the following categories of recipients:

Sub-processors. Trusted third-party service providers who help us operate the platform and deliver the service:

• Cloud infrastructure and database hosting providers.
• LLM API providers, used for automated marking and AI feedback (see section 3).
• Secure payment processing gateways.
• Analytics and performance monitoring services.
• Customer communication and email delivery tools.

These third parties act strictly as our sub-processors. They process your data solely based on our documented instructions to provide services to us, and they are legally prohibited from using your data for their own purposes.

Educators and institutions. If your account is linked to a school, a class or a teacher, we share your academic performance data with your assigned educators. That covers your submitted answers, marks, feedback and topic mastery. We do not share your private conversations with our AI tutor with your school, and we do not share your individual study habits, such as when or for how long you study.

Parents and guardians. If you are under 18, we may share your profile and study data with your parent or guardian on their verified request.

Legal and regulatory authorities. Where we need to comply with the law, respond to a valid legal request, prevent fraud, or investigate a security incident.

We only process your data when we have a valid legal framework to do so:

• Contract: Processing necessary to provide the service, such as account creation, marking your answers, and taking payment.
• Legitimate Interest: Processing to improve our software, keep the platform secure, fine-tune our internal marking algorithms, and prevent fraud.
• Legal Obligation: Retaining billing records to comply with tax and accounting laws.
• Consent: Running non-essential analytics, marketing communications, and cookies. You can withdraw this consent at any time.

Your data is primarily stored within the EU and the UAE. Where our third-party providers process data outside of the EU or the UK, we ensure lawful transfer mechanisms are in place, specifically relying on Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum.

We retain your personal data only for as long as necessary:

• Account and study data: Retained while your account is active, and for up to 2 years after you close it so you can reactivate without losing your progress. After that it is deleted or fully anonymized.
• AI input and output data: Chat logs and other unstructured AI interactions are retained for 12 months from the date they are created, and are then automatically anonymized.
• Billing records: Retained for five years, which UAE financial and accounting law requires.

You can ask us to delete your data sooner at any time. See section 9.

You must be 18 or older to agree to our Terms of Service and pay for a subscription. If you are under 18, a parent or guardian must establish the contract.

• We strictly do not profile children for advertising or marketing.
• If you are located in the EU/UK and are under 16, explicit parental consent is required before we can process your personal data.
• Parents or guardians may contact us at any time to request a copy of their child’s data or mandate its deletion.

Depending on your jurisdiction, you have the right to:

• Request a copy of the personal data we hold about you.
• Request correction of inaccurate data.
• Request deletion or restriction of your data.
• Object to processing that we carry out on the basis of legitimate interests.
• Export your data in a portable format.

To exercise these rights, email contact@fourtyfive.org from the address associated with your account. You also retain the right to lodge a complaint with your local regulatory authority (e.g., the UAE Data Office, the UK Information Commissioner's Office, or your respective EU Data Protection Authority).

We use strictly necessary cookies to operate the site. Non-essential cookies run only with your explicit consent. Please review our Cookie Policy for full details.

We may update this Privacy Policy as our service evolves. Material changes will be posted here with an updated effective date.