Your data

Your applicants’ data stays yours

Skolbot stores and processes applicant conversations in the European Union. An EU residency mode blocks any routing of answer-generation requests outside the EU.

Data is never used to train models. A data processing agreement (DPA) describes each agent, its purposes and its sub-processors.

Applicant

European Union

Skolbot agents
Your CRM
  • Storage and processing in the EU
  • No model training
  • A DPA that describes each agent
  • Incidents reported within 48 h

Four commitments, written into the DPA

The same commitments for every school, in the data processing agreement.

  • A DPA signed with each school
  • Data hosted and processed in the European Union
  • No training: your conversations train no AI model
  • Purge: conversations deleted 6 months after the last message

The school remains the controller

This page covers the Skolbot service: applicants’ conversations with the agents a school installs. The school is the controller. KYX AI is a processor and acts on its instructions, under the DPA.

Processing, purposes and retention

For each agent: the data, the purpose, the sub-processors and the retention period. Annex 1 of the DPA gives the details.

  • Website agent: conversation, contact details if the applicant gives them, program, campus and intake of interest. Purpose: answer and qualify the enquiry. Sub-processors: Google Cloud and Vertex AI (EU), Vercel (interface). Retention: 6 months after the last message.
  • WhatsApp Capture: conversation, WhatsApp number and profile name, contact details if the applicant gives them. Purpose: answer and qualify the enquiry. Sub-processors: Google Cloud and Vertex AI (EU). Retention: 6 months after the last message.
  • WhatsApp Activate: contacts passed on by the school who agreed to be contacted, follow-up history, conversation. Purpose: follow up and book appointments. Sub-processors: Google Cloud and Vertex AI (EU). Conversation retention: 6 months after the last message.
  • Instagram Answer: conversation, Instagram handle and profile name. Purpose: answer incoming messages. Sub-processors: Google Cloud and Vertex AI (EU). Retention: 6 months after the last message.
  • School documents (brochures, programs): read by Reducto, through an EU endpoint, to build the knowledge base.
  • Error tracking: Sentry, EU region, with personal data redacted.

Roles under the GDPR

The school is the controller: it defines the purposes and the legal basis, and informs applicants. KYX AI, which publishes Skolbot, is a processor under Article 28 of the GDPR and processes data only on the school’s instructions. In the United States, the school also stays responsible for compliance with the federal and state privacy laws that apply to it.

Hosting in the European Union

Storage and main processing take place in the EU.

  • Storage and database on Google Cloud, in the EU
  • LLM-agnostic: we use the market’s best-performing models for response time and efficiency, called from endpoints in the EU
  • EU residency mode: no generation request routed outside the EU
  • Residual access from the United States covered by standard contractual clauses

Security measures

The measures are described in the DPA annex.

  • Encryption in transit (TLS) and at rest
  • Multi-factor authentication and least privilege
  • Each client’s data isolated within the platform
  • Chat window limited to authorized domains
  • Error tracking with personal data redacted

No automated decisions

The agents make no decisions within the meaning of Article 22 of the GDPR. Lead scoring ranks each lead as cold, warm or hot, on criteria the school chooses, for example the intended start date, English level or funding. It only helps your team prioritize follow-ups. An advisor always decides what happens next, and the score is not an admission recommendation.

Transparency and the AI Act

Applicants know they are talking to an AI, in line with the transparency obligation of the AI Act. Applicants may be minors: the agents do not ask for age unless the school instructs it in writing.

Incidents and retention

Any data breach is notified to the school no later than 48 hours after discovery. Conversations are deleted 6 months after the last message, as set out in the DPA.

WhatsApp consent

On WhatsApp, the applicant writes first, or has agreed in the school’s CRM to be contacted before any follow-up. One message is enough to stop being contacted.

Applicants under 18

Some applicants are minors. The agents collect only the fields the school needs to handle the request, and do not ask for age. Lead scoring follows the same rules as for an adult: it helps the team prioritize callbacks, and an advisor decides what happens next.

Who is responsible for the answers

Answers are sourced from the school's knowledge base, and each one cites its source. The school reviews the answers during onboarding. When a question goes beyond that content, or the applicant asks for a person, an advisor takes over.

Frequently asked questions

Is our data used to train the AI?

No. Neither Skolbot nor its sub-processors use your data to train models.

Where is the data hosted?

In the European Union, on Google Cloud. Skolbot is LLM-agnostic: we use the market’s best-performing models for response time and efficiency, called from endpoints in the EU.

Who are the sub-processors?

Google Cloud (hosting and Vertex AI, EU), Reducto (reading brochures, EU endpoint), Sentry (error tracking, EU region) and Vercel (interface hosting). The full list is in the DPA.

What about WhatsApp?

The school operates its WhatsApp Business account under its own contract with Meta. Before any WhatsApp Activate follow-up, the school must hold the person’s consent.

How long are conversations kept?

Six months after the last message. The purge is a commitment in the DPA signed with each school.

What about applicants under 18?

The agents collect the minimum the school needs to handle the request, and do not ask for age unless the school instructs it in writing. Lead scoring only helps prioritize callbacks. No decision is automated.

Is lead scoring profiling?

It assesses some of the applicant’s criteria, so the school should have its data protection officer (DPO) assess it. The criteria, the data used and the advisor’s role are defined with the school during setup, so the school can describe them in its record of processing.

Who is responsible if an agent gets an answer wrong?

The school is the controller and approves the content the agents answer from. Each answer is sourced in that content, the school reviews answers during onboarding, and a person can take over the conversation at any time.

Let’s look at your admissions journey.

30 minutes on your programs, your channels and your CRM.

Updated on

One night, played twice.

Read the transcript

At 11:47 pm, Léa, seventeen, is looking for a school. An ad takes her to a website, but a fifteen-field form stops her. Six hours pass: she is not in any CRM. The same night starts again with Skolbot. At 1:12 am, she asks about co-op options and gets an immediate answer. She leaves her first name and number. In the morning, her record and a summary of the conversation are waiting in the CRM. Today, Léa starts her program.