Consent & Data Role Framework
This is a version 1.0 draft prepared for review. It reflects our verified technical and data-protection practices but is pending final management and legal approval. Some sections contain items still under management or legal review and should not be relied upon as final policy.
This framework explains how EDUMOVIA collects separate, purpose-specific consents, how data-controller and processor roles are assigned, and how acceptances are versioned and recorded.
Effective date: 31 August 2026 · Version v1.0
Separate, purpose-specific consents
EDUMOVIA does not bundle unrelated permissions into a single checkbox. Where consent or acceptance is needed we collect it separately: (a) acceptance of the Terms of Service — a mandatory contractual step; (b) acknowledgement of the applicable privacy notice; (c) explicit consent — only where the applicable law requires it for a specific purpose; (d) international-transfer consent — only where the chosen transfer mechanism requires it; (e) marketing communications — always a separate, optional choice, unchecked by default and withdrawable at any time; (f) cookies and analytics — managed through the cookie banner according to the visitor’s jurisdiction.
Data-controller and processor roles
Roles depend on the scenario and are confirmed per relationship [LEGAL REVIEW REQUIRED]. Typically: a student provides data to a tenant, who acts as controller; EDUMOVIA acts as processor for the tenant under the Data Processing Addendum, or as an independent controller for its own website, billing and security operations; a destination university that receives an application acts as an independent controller; AI and infrastructure providers act as processors / sub-processors. The Data Role Matrix in the management pack sets this out in full.
Consent ledger
When a person accepts a document or grants/withdraws a consent, the event is recorded in the platform’s existing audit system with the document, version, jurisdiction, language, timestamp and acceptance type. Records are tenant-scoped and are not visible across tenants. We record what is needed for accountability without logging unnecessary personal data.
Versioning and re-consent
Each document carries a version identifier (for example GLOBAL-PRIVACY/v1.0). A material change increases the version and triggers a re-acceptance policy for affected users. Any mandatory re-consent campaign for existing customers is a [MANAGEMENT GO REQUIRED] action and is not performed automatically.
Certain items marked [MANAGEMENT INPUT REQUIRED] in the text (supervisory authority contact details, data protection / privacy officer, and jurisdiction-specific legal points) are being finalized by EDUMOVIA management and legal counsel and will be updated in a subsequent revision.
For questions about our legal and data protection practices, please contact us.
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