Annex 1 to the PUB-avtal, part A: The processing
Belongs to PUB-avtal version 1.0 · Effective from 4 October 2026 · Last updated 4 October 2026
Viafocus AB, reg. no. 559547-4882
The annex is available in Swedish and English. The Swedish text prevails if they differ. The agreement: /en/pub-avtal.
In short
Part A describes the processing. Part B, the security measures in detail, is provided on request.
- Who is responsible?
- The school's organiser (huvudman) is the controller. Viafocus AB is the processor.
- Where is the data?
- Our servers run in the Netherlands (Railway), our databases in Frankfurt (Neon), the web app in Stockholm (Vercel), and all AI on Microsoft Azure in the EU. → section 1
- Screen images?
- Shown only while a teacher has the pupil in view, and never stored. The school can switch them off. → section 2
- How long is data kept?
- The active page or app is kept only until the computer disconnects. Activity history only if the school switches it on. → section 3
- What is never collected?
- Focuspilot never reads keystrokes, passwords, cookies, camera, microphone or the contents of files. → section 5
1. How the data moves
The flow in short. Which sub-processor does what, and where, is on /en/subprocessors.
The pupil's computer sends, encrypted, which page or program is open, its status and blocked attempts while it is connected. Screenshots are sent only while a teacher has the pupil in view.
Only the latest from a computer is kept, and only while it is connected. Screenshots are never stored. Accounts, classes, lessons, answers and results are stored in our databases, as is activity history if the school has switched it on.
All AI runs within the EU (Microsoft Azure), or with the provider the school itself has an agreement with if the school uses its own AI key.
2. The data, why, and where it is
Which data exists depends on which features the school uses.
| Data | Why | Where | Country | Sub-processor |
|---|---|---|---|---|
| Account: name, email, school, class or group, year, role | Sign-in and the right access | Database | Germany | Neon |
| Sign-in: sessions, one-time codes, sign-in attempts | Secure sign-in | Database | Germany | Neon |
| Live activity: active page or program and its title, status, blocked attempts | The teacher's overview. Only the latest is kept, even when no teacher is looking. | Memory on our servers | Netherlands | Railway |
| Screenshots and the list of open tabs and programs | The teacher's view of a pupil. Shown only while a teacher has the pupil in view. | Not stored, only passed on | Netherlands | Railway, Cloudflare (network) |
| Exam events, for example the pupil leaving the test | The teacher's picture of the test | Memory on our servers | Netherlands | Railway |
| Activity history, only if the school switches it on: mode changes and when the pupil connected | Follow-up for the school | Database | Germany | Neon |
| Teacher commands: which teacher sent which command to which class or group, and when | Operations, support and traceability | Database | Germany | Neon |
| Computer: random id, platform, app version and when it was last connected | Link the computer to the right pupil and check that it belongs to the school | Memory on our servers | Netherlands | Railway |
| Studio: lessons, answers, results, test accommodations, the teacher's comments and private notes | Teaching and tests | Database and file storage | Germany, Europe | Neon, Cloudflare |
| AI chats and attached files | The teacher's AI assistant | Database and file storage; processed by AI | Germany, Europe; AI within the EU | Neon, Cloudflare, Microsoft Azure |
| The class overview when the teacher asks the AI assistant, for example pupils' names, active page, the class's mode and test status | Answers to the teacher | Processed by AI and saved in the teacher's AI chat | EU | Microsoft Azure, Neon |
| Traces of AI calls, for example model, time and volume | Checking the quality of AI answers | Tracing service | EU | Langfuse |
| Technical and security logs: IP address, times, errors | Operations and security | Database and server logs | Germany, Netherlands | Neon, Railway |
| Email to users: address and message | Sign-in codes and notifications | Sent | EU | Lettermint |
| Optional, only if the school chooses: personal identity number, profile picture | Match the right pupil on import, show a picture | Database and file storage | Germany, Europe | Neon, Cloudflare |
The data comes from the school's directory (Google or Microsoft), from files the school imports, from what teachers and pupils write and from the school's computers.
3. Retention
These are the longest times we keep the data. The school can give us other instructions.
| Data | How long |
|---|---|
| Screenshots | Not stored |
| Active page or program | Only the latest. Deleted when the computer disconnects. |
| Status, blocked attempts during the lesson and exam events | At most 24 hours |
| Details about the computer | 7 days after the last connection |
| Activity history | Off by default. The school chooses 7 to 365 days; 90 days is the default when it is on. |
| Teacher commands | 90 days |
| Technical logs | 90 days, or the period the school has chosen for activity history if that is longer |
| Security logs | 12 months |
| AI chats | Until the teacher deletes them, at the latest after 12 months without activity |
| Files attached in the AI chat | 30 days |
| The Studio bin | 30 days |
| Lessons, answers and results | Until the teacher or the school deletes them, or the agreement ends |
| Pupils the school has archived | The school chooses 1 to 36 months; 12 months is the default |
| Deletion on request and after the agreement ends | As in the data processing agreement, section 11 |
4. Sub-processors
Every sub-processor, what it does, where the data is held and which transfer safeguard applies: /en/subprocessors. Changes are announced in advance under the PUB-avtal, section 8.
5. What Focuspilot never collects
What the pupil types and which keys they press.
Passwords and cookies.
Camera and microphone. Sound is never recorded.
The contents of files.
No AI sets scores or grades, judges emotions or looks for cheating. The teacher assesses.
6. What the school controls
Whether activity history is kept, and for how long (7 to 365 days).
Whether teachers may see which page or program is open, the list of open tabs and programs, and screenshots. Each can be switched off for the whole school.
Sleep outside school hours. The school switches it on once its school hours are set.
Part B: Security measures
Part B, the security measures under Article 32, is provided to the customer on request to dataskydd@viafocus.net. A summary is at /en/security.
Change history
First version.