This Data Protection Impact Assessment (DPIA) is an internal and institutional document prepared to
demonstrate how SuperMind Education Services (“SuperMind”, “we”, “our”, or “us”) protects personal data
in line with NDPR, GDPR, FERPA, COPPA, and other global data protection standards. It is intended for
schools, universities, regulators, auditors, partners, and investors who require assurance that our
platform processes data safely and lawfully.
1. Executive Summary
SuperMind Education Services is an AI-powered educational platform used by students, teachers, schools,
partners, and institutions. The platform processes sensitive and high-risk data, including student
identities, academic records, exam scripts, AI-graded assessments, wallet transactions, and teacher
information.
This DPIA describes what data we process, why we process it, how it flows through the system, what
risks are involved, and which safeguards we have implemented to reduce those risks to an acceptable level.
The purpose is to ensure that our processing is transparent, necessary, proportionate, and compliant with
applicable laws, especially where minors and exam records are involved.
2. System Overview
SuperMind provides a unified digital environment for learning and school management, including:
AI-assisted exam grading (objective and theory scripts)
Student and teacher dashboards
Lesson uploads (videos, notes, and materials)
Classroom forums and announcement tools
Academic timetables and attendance features
Partner advertisement and impression tracking system
Wallet and coin system for in-platform payments
Cloud-based media storage via Backblaze B2
Payment processing through Flutterwave
The platform is suitable for primary, secondary, tertiary, and vocational institutions and can operate
across multiple countries and regions.
3. Purpose of This DPIA
This DPIA is required because SuperMind processes:
Children’s and students’ personal data
Exam scripts, grades, and academic profiles
Payment-related data and wallet balances
Files and content stored in cloud infrastructure
Data processed by AI systems for grading and analytics
These activities are categorised as high-risk under NDPR, GDPR, FERPA, and similar frameworks. The DPIA
helps us:
Identify and document potential privacy and security risks
Describe the measures we use to mitigate those risks
Demonstrate accountability and compliance to institutions and regulators
Ensure that our processing is fair, lawful, and transparent
4. Description of Data Processing
4.1 Categories of Data Collected
A. Personal Identification Data
Full name
Email address
Phone number
Password (stored in encrypted/hashed form)
Country, state, and city
School, university, department, or class information (where applicable)
Profile photo or avatar (optional)
B. Educational & Academic Data
Uploaded exam scripts and answer sheets
AI-graded responses and scoring breakdowns
Grades, scores, and performance analytics
Attendance, timetables, and course schedules
Lesson content, notes, and teaching materials
Teacher feedback and comments on student work
C. Usage & Interaction Data
Forum posts, classroom conversations, and replies
Likes, reactions, and other engagement signals
Lesson, video, and resource viewing history
Login and navigation patterns (for analytics and stability)
D. Technical & Device Data
IP address and approximate geo-location
Browser type and version
Device type and operating system
Login timestamps and session identifiers
Cookies and similar technologies used for authentication and security
E. Payment & Wallet Data (via Flutterwave)
All financial transactions, such as wallet top-ups, coin purchases, subscriptions, and partner advertisement
payments, are processed securely by Flutterwave. SuperMind does not store card numbers, CVV,
or full bank account details.
We may receive and store:
Transaction reference and payment status
Amount, currency, and time of payment
Wallet and coin balances related to user accounts
F. Files & Media Stored via Backblaze B2
Lesson videos and images
PDF notes and scanned exam scripts
Partner advertisement images and media
Other educational attachments uploaded through the platform
4.2 How Data Flows Through the System
Users register and create accounts → identification data stored in our secure database.
Students and teachers upload scripts or lessons → files stored in Backblaze B2.
AI processes exam content → grades and feedback written back to the SuperMind database.
Users purchase coins or subscriptions → payments handled by Flutterwave; references returned to SuperMind.
Users interact via forums and dashboards → activity and interaction logs stored for functionality and analytics.
Institutions may view student performance reports → restricted to authorised institutional accounts.