Privacy Policy

Last Updated: 15/10/2026

At Anytime Creativity, we are committed to protecting your personal data and privacy. This Privacy Policy outlines how we collect, use, store, and share your personal information in compliance with the General Data Protection Regulation (GDPR).

1. Who we are and our role

Anytime Creativity Limited (‘we’, ‘us’) is a company registered in Ireland, with its registered office at 47 Clonturk Park, Drumcondra, Dublin 9, D09E6X9. When a university or other institution (the ‘Customer’) uses the platform with its students and staff, the Customer is the data controller and we act as its data processor, following its documented instructions under a data processing agreement. We are the controller only for personal data about visitors to our website, people who request a demo, and our own business contacts, which we hold in our CRM

2. Personal Data We Collect

• Identification and contact data: name, email address and the institution a user belongs to
• Work and communications: documents, images, prototypes, comments and peer feedback that users submit
• Progress and activity data: challenge participation, stage progress, timestamps and activity logs
• Engagement indicators: patterns in usage over the course of a challenge, used to estimate motivation and engagement and to prompt students with motivational nudges
• Device and usage data: browser type, operating system, IP address and interaction data, collected through Microsoft Clarity
• Authentication data: sign-in events and, for users with a local login rather than single sign-on, a hashed password
• AI feature data: the text a user submits to the optional AI stage and the response returned

We do not ask for special category data (such as health, ethnicity or religion) and users should not enter it.

3. How We Use Your Data

We use your data for the following purposes:

• To create and manage accounts and deliver the challengesTo facilitate participation in challenges, track progress, and issue digital badges
• To show educators student progress and produce each student’s impact portfolio
• To estimate engagement over a challenge and prompt students with motivational nudges
• To provide support, keep the platform secure and fix faults
• To provide the optional AI coaching feature
• To improve and optimise the platform, using anonymised and aggregated usage data wherever possible
• To meet legal obligations

4. Legal Basis for Processing Your Data

For users at a Customer, the Customer decides the legal basis (public universities usually rely on their public task) and we process on its instructions. For our own controller activities we rely on legitimate interests, such as security, support and running our business, and on consent where the law requires it, including for analytics cookies.

5. Data Storage and Security

• Your personal data is stored on secure servers hosted by Amazon Web Services (AWS) in Ireland.
• We implement technical and organisational measures to protect your data against unauthorized access, alteration, disclosure, or destruction.
• AWS provides robust security infrastructure, ensuring compliance with EU data protection regulations.

6. Data Sharing and Disclosure

We may share your data with:

• Amazon Web Services: Hosting, storage and backups (Ireland)
• OpenAI: Optional AI coaching feature (U.S)
• Legal Authorities: If required by law or to enforce our rights, we may share data with legal authorities.
• Microsoft Clarity: Usage analytics
• Microsoft and Google: Single sign-on, email address only
• Our CRM database supplier: Hubspot, Inc. (No student or user data is stored here, only buyer details.)

We also share data with staff and contractors who need it to run the platform, and with authorities where the law requires it. We do not sell personal data or share it for direct marketing. We tell Customers before we add or replace a sub-processor.