Effective Date: 08 January 2026
Applies to: All Kunduz services, including AI-powered features such as KAI
1. Purpose and Scope
This policy sets out Kunduz’s approach to:
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Student safeguarding
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Data protection and privacy
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Responsible and safe use of digital and AI-powered educational tools
It applies to all users of the Kunduz platform, including students, parents or guardians, schools, and authorized staff.
This policy supplements Kunduz’s:
In the event of any inconsistency, the provision that offers greater protection to students and children shall apply.
2. Core Safeguarding Principles
Kunduz is an education-first platform designed for student use under adult and school supervision.
Across all features and services, Kunduz operates under the following principles:
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Student wellbeing takes priority over functionality or engagement
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All educational interactions must be age-appropriate and culturally suitable
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Digital tools must support—not replace—teachers, parents, and schools
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Transparency, oversight, and accountability are essential
3. Educational Purpose and Role Boundaries
All Kunduz services, including AI-assisted tools such as KAI, are designed solely to support learning.
Kunduz services:
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Assist with academic understanding, practice, and learning support
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Align with school curricula and educational objectives
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Maintain a respectful, neutral, and non-judgmental tone
Kunduz services do not:
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Replace educators, parents, or school staff
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Provide personal, medical, psychological, or legal advice
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Challenge family, school, cultural, or institutional authority
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Encourage students to keep secrets or communicate outside approved channels
4. Content Restrictions and Safe Use
To protect students, Kunduz applies strict content boundaries across the platform.
Kunduz services do not engage in or promote:
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Religion or religious instruction
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Politics or political ideologies
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Gender or sexuality-related discussions
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Social or cultural debates unrelated to curriculum
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Romantic or interpersonal relationship advice
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Any content that is age-inappropriate or culturally unsuitable
All responses and educational materials are designed to be:
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Curriculum-focused
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Neutral and respectful
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Appropriate to the student’s age and educational level
5. Student Wellbeing and Safeguarding Response
5.1 Handling of Sensitive or Distressing Expressions
Kunduz does not function as a counseling, therapy, or crisis-management service.
If a student expresses distress, emotional difficulty, or seeks personal advice:
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The platform does not attempt to diagnose or intervene directly
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Responses are limited to supportive, non-directive guidance
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Students are encouraged to seek help from trusted adults, such as:
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Parents or guardians
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Teachers or school counselors
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Officially recognized local support services (where applicable)
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5.2 Safeguarding Alerts and School Oversight
Certain features within Kunduz, including AI-powered services, may include mechanisms to identify potential safeguarding or wellbeing risks.
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These mechanisms are designed to support school safeguarding responsibilities
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Alerts are visible only to authorized school staff
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Schools review and handle alerts according to their internal safeguarding procedures
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Kunduz does not replace or override school safeguarding decisions
6. Data Protection and Privacy-First Design
Kunduz applies privacy-by-design and child-focused data protection principles across the platform.
6.1 Data Minimization
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Only data necessary to deliver educational services is processed
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Collection and retention of personal data are strictly limited
6.2 Use of Student Data
Student data is used solely to:
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Provide and improve educational services
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Ensure platform safety and quality
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Meet legal, regulatory, and safeguarding obligations
Student data is never used for:
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Advertising or behavioral profiling
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Sale to third parties
6.3 Access Controls and Security
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Access to student data is restricted to authorized personnel
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Role-based access controls are enforced
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Security monitoring and logging are in place to prevent misuse
6.4 Use of Authorized Service Providers
Kunduz works with carefully selected and authorized service providers to support the operation, security, and delivery of the platform.
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Authorized service providers process data solely on Kunduz’s instructions and only to the extent necessary to provide contracted services.
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Data may be stored or processed in jurisdictions where Kunduz or its authorized service providers operate, subject to appropriate legal, contractual, and security safeguards.
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Authorized service providers are contractually prohibited from using student data for their own purposes or for advertising, profiling, or commercial exploitation.
6.5 Data Retention, Backups, and Archiving
Kunduz maintains data retention practices that balance operational needs, legal obligations, and student privacy.
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Data may be retained in secure backups and archives for limited periods to support business continuity, disaster recovery, security incident response, and compliance obligations.
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Backups and archives may include core application data, educational content, and records of platform interactions where necessary for operational or compliance purposes.
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Access to backup and archived data is strictly restricted, monitored, and protected using appropriate technical and organizational safeguards.
6.6 Cookies and Tracking Technologies
Kunduz uses limited cookies and similar technologies to ensure platform functionality, security, and performance.
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Cookies and similar technologies are used for essential functionality, service reliability, security monitoring, and aggregated analytics.
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Kunduz does not use cookies or tracking technologies for advertising, behavioral targeting, or commercial profiling of students.
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Personal data collected through cookies or similar technologies is not sold or shared for advertising purposes.
7. Responsible Use of AI and Automated Systems
Where Kunduz uses AI or automated technologies:
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Systems are designed with conservative safety constraints
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Content moderation and filtering are applied
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Human oversight remains central
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AI outputs are evaluated regularly for quality, bias, and safety
AI features are assistive tools and do not operate autonomously in safeguarding or disciplinary matters.
8. School, Parent, and Guardian Responsibilities
Kunduz services are intended to be used:
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Under school supervision or parental guidance
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In line with institutional policies and local regulations
Schools and guardians are responsible for:
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Informing students about appropriate use
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Integrating Kunduz into existing safeguarding frameworks
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Responding to safeguarding alerts where applicable
9. Legal and Regulatory Compliance
Kunduz operates in accordance with:
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Applicable data protection laws
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Local child digital safety and education regulations
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Industry best practices for student-facing platforms
Where regional requirements differ, Kunduz applies the stricter standard.
10. Policy Review and Updates
This policy is reviewed periodically to reflect:
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Changes in law or regulation
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Product or technology updates
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Evolving educational and safeguarding standards
Material updates will be communicated through Kunduz’s official channels.
11. Contact and Accountability
For questions or concerns related to safeguarding, data protection, or responsible use: Kunduz Safeguarding & Data Protection Team