Privacy policy
Last updated: 10 November 2026
This policy explains what personal data Sembl holds, why, who else handles it, how long it stays and what you can do about it. It covers the Sembl app. It does not cover Sembl Play at play.sembl.app.
The short version
- Sembl is for teachers. We do not ask for or want any information about a child.
- We use what we hold to run your account and the service, and to improve it. We do not sell it and we do not show advertising.
- There are no analytics or advertising cookies, and no tracking pixels in the emails the app sends.
- We never receive or store your card details.
- To ask for a copy of your data, or to have it deleted, write to admin@sembl.app.
1. Who we are
SEMBL AS is the controller of your personal data, which means we decide how and why it is used.
SEMBL AS, organisation number 931 699 741
Stoknesvegen 15, 6008 Ålesund, Norway
admin@sembl.app
We have not appointed a data protection officer. Write to the address above about anything in this policy.
2. Please keep children's information out of Sembl
Sembl has no student accounts, and nothing in it is built to hold a child's name, work, score or behaviour. Some boxes let you type words, such as a playlist's title or a search. Please never type a child's name or anything about a child into Sembl. If you have, tell us and we will help you remove it.
Accounts are for adults. A class may use Sembl with its teacher, for example on the board at the front of the room, but that use is under the teacher's account and we collect nothing about the children. If you believe a child has made an account, tell us and we will delete it.
3. What we hold, why, and our legal basis
Data protection law requires a legal basis for each use. Ours are:
- Contract: we need it to provide what you signed up for.
- Legitimate interest: it is needed for a real purpose of ours, and that purpose is not outweighed by your rights. You may object to these uses (section 9).
- Consent: you said yes, and you can take it back at any time.
- Legal obligation: the law requires it.
If you have an account
| What | Why | Basis |
|---|---|---|
| Email address | Signing you in and writing to you about your account | Contract |
| Your name, if your sign-in provider sends it or our earlier system held it | Addressing you | Contract |
| How you sign in, and your provider's id for you if you use Google or Microsoft | Letting you sign in the same way again | Contract |
| Your role, setting, the grades and topics you teach, the standards you are on and your standards framework | Showing you what suits your teaching | Contract |
| The same grades and topics, and whether you have opened tasks | Choosing which marketing emails you get and what they offer, only if you may be sent them (section 10) | Legitimate interest: sending you something relevant |
| Playlists, saved tasks and saved playlists of ours, boards you made in the tools, the words you type into them, and how you have shared any of them | The features themselves | Contract |
| A class puzzle you send in: its shapes and numbers, its level and class label, a country if you choose one, a name if you choose one, when you would like it shown, and our decision on it | Showing it to other classes, and checking it first | Contract, and legitimate interest for the checking |
| An enquiry about Sembl for Schools: your school's name, your role, roughly how many teachers, where you asked from, when and when we dealt with it | Writing back to you | Legitimate interest: you asked us to |
| Free access we gave you: until when, who gave it and why | Giving you the access, and answering for it later | Contract, and legitimate interest for the reason |
| Your place in a course or in a game you saved part way | Letting you carry on, on any device | Contract |
| Whether you have started a trial, and when | One trial per person | Contract |
| A webinar you sign up for, and when you signed up | Sending you the way in, the reminders and the recording | Contract |
| Your school or district and your place in it, including a job title if one was given to us | Giving you the access your school arranged, and our dealings with that school | Legitimate interest: providing what your school bought for its teachers |
| Your plan: its status, currency, renewal date and Stripe's reference numbers | Knowing whether you have premium access | Contract |
| Your email address, looked up at Stripe when you sign in | Finding any plan you already hold, so that you get your access | Legitimate interest |
| Invoices and payment records, held by Stripe and our accountant and not in the app | Keeping the accounts | Legal obligation |
| How you heard about Sembl, when last seen, and the reference number from our earlier system | Understanding how people find us, knowing when an account has gone quiet, and matching accounts during the move | Legitimate interest |
| Your signed-in sessions: IP address and browser details | Keeping you signed in and your account secure | Contract, and legitimate interest for security |
| What you do in the app (see below) | Deciding what to build, keeping your allowances and places, and choosing what your own dashboard shows you | Legitimate interest, and contract where it keeps your place or an allowance |
| Your email address, for marketing email | Sending ideas, news and offers about Sembl (section 10) | Consent where you said yes. Otherwise legitimate interest, within the law's rule for existing customers |
| A record of what you told us about marketing email, including the words you were shown | Proving what you agreed to, and never emailing somebody who said no | Legal obligation |
| A record of which emails we have sent you, not their contents | Not sending you the same email twice | Legitimate interest |
What you do in the app. While you are signed in, we record events under your account: for example opening or printing a task, starting or ending a game, finishing a task in a playlist, searching, filtering, starting a trial, sharing a playlist or pressing a button on your dashboard. A search is recorded with the words you searched for. An event never records who in your class was asked, or anything about a child. Your dashboard reads your own events to decide what to offer you, including how much premium it shows you. Whether you have opened a task can also decide which marketing emails you get, if you may be sent them.
Live webinars. We record them and put the recording on Sembl for teachers to watch. If you turn on your camera or microphone in one, or write in its chat, that may be in the recording (legitimate interest: letting teachers who could not come watch it).
If you do not have an account
Visiting. When you are signed out, we record what was opened or searched for and when, with no account or identifier attached (legitimate interest: learning what teachers look for). We set no cookie to do this. Please do not type somebody's name into a search box: the words are kept.
Asking about Sembl for Schools. If you fill in that form on a workshop page, we keep your name, email address, school, role, roughly how many teachers there are, where you asked from and when. We use these only to write back to you (legitimate interest: you asked us to). It does not sign you up for marketing.
Writing to us. We keep what you send so that we can answer it (legitimate interest).
If you are credited on a task
If your work is on Sembl, we may hold your name, a short biography, a picture and your website or public profiles, and show them with your work (legitimate interest: crediting you is the point). We usually get these from you or from what you publish yourself, and some came from our earlier system. We may also hold the date you agreed terms with us (contract). Ask us if you would like this changed or removed. If you present a webinar, the same goes for your name and picture, and the recording shows you.
Technical records
Our hosting and database suppliers keep technical logs of requests and sign-ins, which include IP addresses. These keep the service running and secure (legitimate interest). We do not use them to follow individual visitors.
Do you have to give us this?
Only your email address is needed to have an account. Without it we cannot sign you in. Everything else is optional or arises from using the feature in question.
4. Where we get data from other than you
- Your school or district, if it has a plan with us. It may give us your work email address so that you get the access it paid for. We may make your account ready before you first sign in, and email you to say your school has added you.
- Google or Microsoft, if you choose to sign in with them. They send us your email address and name, and Google also sends the address of your picture, which we never use or show.
- Stripe, which tells us the status of a subscription.
- Our earlier system, if you used Sembl before this app. We may move your account across: your address, name, grades, the dates of your trial, when you were last seen, your playlists, saved tasks and school. We do not move your activity or your playlist notes. We rely on contract, because this is the account you already have with us.
5. Who else can see what you make or share
Everything of yours is private unless you choose otherwise.
- Staff at Sembl can see what they need to run the service. That includes your email address, name, school and when last seen if you belong to a school with us; your email address and plan if you subscribe; your email address and name if you sign up for a webinar; and, when checking the emails we send, your grades, topics, trial dates, marketing choice and what an email would say to you. The app's rules do not let staff read your playlists, saved tasks, saved boards or your progress through a course, with one exception: to help you, or to check that something is right before you arrive, a member of staff can see Sembl as you see it, for up to thirty minutes at a time. They see what you would see, those things included, and cannot change anything while they do. Each time is recorded, with who and when. Apart from that, we keep no log of what staff look at. The people who run Sembl can also reach the whole database directly and do so by hand, for example to answer a request from you or to fix a fault. No log records this.
- A playlist shared by link can be seen by anybody who has the link. It shows the title, headings and tasks, and does not say whose it is. You can turn the link off at any time.
- A playlist shared with your school's team can be read and copied by its members while the school has a plan. The screens do not say whose it is, but a colleague with the technical know-how can read your account's reference number, and in some cases match it to you. A colleague's copy is theirs, and stays if you later delete yours. You can also let colleagues in that team change its tasks and headings: everyone, or the ones you choose. Only you can rename it, change how it is shared or delete it.
- Your name and email address are shown to colleagues in your school's team who put a playlist in its library, so that they can choose you to edit it. Nobody outside your school sees them this way.
- A class puzzle you send in can, once approved, be shown to signed-in teachers using Sembl and printed on their sheets. If you choose to have your name on it, the credit reads along the lines of "Made by Ms Smith's Grade 3 class in Norway". You see the credit before you send, and you can leave your name off. Staff read a name before anybody else sees it. Some puzzles from teachers staff have already approved are scheduled automatically by set rules. Anything out of the ordinary waits for a person.
- School administrators can add and remove their school's teachers. They see each teacher's email address, whether that teacher has signed in, and their name once they have. They see nothing about what a teacher does in Sembl. They can also read the membership records of their school, including account reference numbers and any job title.
6. Suppliers and other recipients
We use these companies to run Sembl. Those marked processor handle your data for us, under a data processing agreement.
| Company | What they do | What they receive | Where | Transfer safeguard |
|---|---|---|---|---|
| Supabase Pte. Ltd. (Singapore) | Database, sign-in and file storage (processor) | Everything in section 3 | Hosted in Ireland. Supabase may reach it from outside the EEA | EU standard contractual clauses |
| Vercel Inc. (USA) | Hosting the app (processor) | Requests as they pass through, including IP addresses, and data the app handles for you | Served from nearby networks. The app's server code runs in the USA | EU standard contractual clauses |
| Plus Five Five, Inc., trading as Resend (USA) | Sending email (processor) | Your email address, name and the email itself, which can mention your grades and topics or a webinar you signed up for | Sent from Ireland. Resend is a US company and may reach it from the USA | EU standard contractual clauses |
| Stripe Payments Europe, Limited (Ireland), with Stripe, LLC (USA) | Taking payments. Stripe is a controller for some of this data, under its own privacy policy | Your payment details, which you give directly to Stripe. When you sign in, your email address may go to Stripe so that we can find any plan you have | EEA and USA | Stripe's data transfer terms |
| Anthropic Ireland, Limited | The AI model staff use to draft tasks (processor) | Task material and instructions typed by staff. The app sends it no teacher's or visitor's data. Anthropic's terms do not let it train its models on this. Staff also use its coding tool, which can see what a script prints | USA | EU standard contractual clauses |
| Formagrid Inc, trading as Airtable (USA) | Our earlier system (processor), until it is switched off | Account details of people who used it. The app sends it only task content | USA | EU standard contractual clauses |
| Softr and MailerLite | The rest of our earlier system, and its newsletter, until they are switched off | Account details of people who used it, and the newsletter's addresses. The app sends them nothing | Under their own terms | Under their own terms |
| Cloudflare, Inc. (USA) | Directing our web address to the app (DNS) | Technical lookup requests | Global | EU standard contractual clauses |
| Lovable | Hosting some of our older tasks, at ontheline.sembl.app, frames.sembl.app and choralcount.sembl.app | Your IP address and browser details when you open one of those tasks | Served through Cloudflare's network | Under its own terms |
| Our email (admin@sembl.app) | What you send us, and our replies | Global | Under Google's terms |
Our accountant in Norway receives invoices and supporting records, which we must keep by law.
We may also disclose data where the law requires it, or to a buyer of the business, who would be bound by this policy.
Companies you choose to contact
These are not our suppliers. They handle your data under their own policies, and some of them are outside the EEA.
- Google and Microsoft, if you press their sign-in button. They learn that you signed in to Sembl. Nothing from them loads until you press.
- Zoom, if you press the link to join a live webinar. Google and Microsoft, if you press to add a webinar to their calendars. The app sends them nothing about you; your browser goes to them.
- Google, Canva, Mathigon and other sites that host some of our tasks. YouTube and Vimeo, which play some videos. Your browser contacts them when you open that task or press play, or when you move on to that task while teaching a playlist. Opening the direct link to a workshop's task can also do it. They then receive your IP address and may set their own cookies. They do not load when you simply browse the library.
- Sites we link to, which open in a new tab.
Transfers outside the EEA
The USA and Singapore are outside the European Economic Area. We rely on the European Commission's standard contractual clauses, or the other safeguards shown above. You can ask us for a copy at admin@sembl.app.
7. How long we keep it
Apart from webinar sign-ups, nothing in the app deletes data on a schedule yet. So most of what we hold stays until you remove it or your account is deleted, and this table says so.
| What | How long |
|---|---|
| Your account, what you made and what you do in the app | While your account exists. Your playlists and boards are not removed because a trial or plan ended |
| An account made for you that you never used | Until you or your school ask us to delete it |
| Your place in a course | Until you press "Forget my progress" or your account is deleted |
| A game saved part way | Until you finish it, start a new day or your account is deleted |
| A webinar you signed up for, and the record of which emails we sent you about it | Twelve months after the webinar, then deleted automatically, or when your account is deleted. Cancelling removes the sign-up at once, and the record of emails stays the twelve months |
| Signed-out visit records and daily counts | Without limit, as no account or identifier is attached |
| A class puzzle sent in | While your account exists. If your account is deleted, a puzzle already shown stays, with your name taken off |
| Enquiries about Sembl for Schools | We mean to delete them by hand two years after we dealt with them, or sooner if you ask. Nothing does this automatically yet |
| A credit on a task | While the work is published, or until you ask us to remove it |
| What you send us by email | As long as we need it to deal with what you asked |
| Invoices and accounting records | At least five years after the end of the accounting year, as Norwegian bookkeeping law requires. These are held by Stripe and our accountant, not in the app |
| Technical logs and backups | On our suppliers' own cycles |
What stays when an account is deleted
We delete your account and what is held about you in the app, including our copy of your subscription status. Some things remain, and we would rather name them:
- A one-way hash of your email address, only if you started a trial or had your own subscription, so that deleting an account and signing up again does not give a second free trial (legitimate interest). It cannot be turned back into your address, but somebody who already holds your address could test for a match, so we treat it as personal data. We keep it for as long as that rule exists. No screen in the app shows it.
- Accounting records, held by Stripe and our accountant as above. The law requires us to keep these.
- Anything already passed on by your own choice, such as a colleague's copy of a playlist or a puzzle already shown, with nothing saying it was yours.
- A task you helped make, which stays with your account's name removed. A public credit stays on your work until you ask us to remove it as well, so please say if you would like that.
- Sign-in logs, which can hold your address and IP address. Deleting an account does not reach them today.
- Copies held elsewhere for a time: backups until they expire, and what Resend holds of emails sent to you, on its own schedule. If our earlier system still holds you, we delete you there too.
- The record of your request, so that we can show we answered it (legal obligation).
If you pay by subscription, we cancel it at Stripe before deleting your account. Please tell us if you have a plan.
8. Cookies and storage on your device
We store only what we need for something you asked for, which is why Sembl has no cookie banner. There are no analytics or advertising cookies.
| Name | Type | What it is for | How long |
|---|---|---|---|
sb-…-auth-token | Cookie | Keeps you signed in | Up to 400 days, or until you sign out |
sb-…-auth-token-code-verifier and similar | Cookie | Protects you while you sign in | Until sign-in finishes. If you abandon it, up to 400 days |
sembl_gate | Cookie | Remembers the site password, while the app is unreleased. Names nobody | 180 days |
sembl:learn:progress:… | Local storage | Keeps your steps through a course on this device. Only if you press "Save my progress on this device" | Until you press "Forget my progress" |
sembl-workshop-… | Session storage | The presenter's timer and place during a workshop | Until the tab closes |
The emails the app sends have no tracking pixels and no tracked links.
9. Your rights
You have the right to:
- See what we hold about you, and have a copy.
- Correct anything wrong or incomplete.
- Delete your data, subject to section 7.
- Limit how we use your data while a concern is sorted out.
- Take your data with you, in a common format, where we hold it by contract or consent.
- Withdraw consent at any time. That does not undo what was done before.
You also have the right to object to anything we do on the basis of legitimate interest. If you object to marketing email, including using your activity to choose it, we always stop. Otherwise we will look at what you have asked and answer you. Most of these uses cannot yet be switched off for one person inside the app, so we will tell you plainly what we can do, and that may include deleting your account if you want that.
To use any of these, write to admin@sembl.app. It costs nothing. We check the request is from you by replying to the address on your account, and answer within one month of knowing that it is. If it is really complicated, we will tell you within that month that we need up to two more. There are no screens for most of this yet, and a person deals with each request. Some things you can do yourself: changing what you teach, deleting a playlist or board, and pressing "Forget my progress". To change your name or address, write to us.
We do not make decisions about you by purely automated means that have a legal or similarly significant effect.
If you are unhappy, please write to us first if you can. You can complain at any time to the Norwegian Data Protection Authority, Datatilsynet, at datatilsynet.no, or to the data protection authority where you live or work.
10. Email
About your account. Sign-in codes are part of the service, and you get them whatever your marketing choice is. Any note we send about your trial or account is the same, including one saying your school has added you and, if you are its administrator, reminders that its plan is ending. So are the confirmation, reminders and recording note for a webinar you signed up for. Signing up for a webinar is never permission for marketing.
Ideas, news and offers. The app sends these only if the record in section 3 says it may:
- If you start a trial, we may send you them about similar Sembl products unless you tick the box that says no. Every one has a link to stop them.
- Otherwise we send them only if you said yes.
Pressing Stop takes one press with no signing in. It writes a new record, and the app sends no more. You can also write to admin@sembl.app.
Our older newsletter. Some people also get a newsletter from our earlier system, sent through MailerLite. Pressing Stop does not reach it, and it has its own Unsubscribe link. Write to admin@sembl.app and we will stop both.
11. Keeping data safe
Access to every table is denied by default, and rules name who may read what. Keys that open everything are never sent to your browser. They are held on our server and by the people who run Sembl, for work done by hand. Task files in private storage are served through short-lived links. We have a process for handling a breach and telling the authority, and you where the law requires it.
No system is perfectly secure. Tell us at admin@sembl.app if you find a problem.
12. Changes
We will change this policy when what we do changes. If a change matters, we will tell you by email or in the app before it takes effect. The date at the top is when it last changed.