Competency Assessment Module Terms
Competency Assessment Module Terms
Product: Kluppy Connect — School Plan Version: 1.1 · September 2026 Accepted electronically by the school's management from the admin panel. These terms supplement the B2B Terms of Service and the Data Processing Agreement (DPA v2.1), both of which remain in force.
Replaces the paper addendum foreseen in the assessment plan: the School does not sign a separate document; it accepts these terms on the platform, with the version, date, user and IP address recorded, and receives confirmation by email (electronic form under Art. 28(9) GDPR).
1. What the module is, and what it is not
1.1. For each student and period, the module produces an evidence report with the student's keyboard-writing measurements (standard words per minute, keystrokes per minute, accuracy, level reached, accumulated keystrokes and sessions worked), obtained from a common fixed-text test and from ordinary practice, and places them in achievement bands according to the cut-points agreed with the School (DPA, clause 12.1).
1.2. The report is supporting evidence, not a grade (DPA 12.2). By itself it has no effect on the student.
1.3. Bands are obtained through deterministic, auditable arithmetic rules. No artificial-intelligence systems, profiling or inferences about personal characteristics are involved, and the student's age is not processed (DPA 12.3). The common test uses a fixed, versioned bank of texts that is not AI-generated, precisely so that the module stays outside Annex III of Regulation (EU) 2024/1689 (Kluppy AI Risk Classification, §3.4).
2. Who grades
2.1. The grade is always determined by a person at the School, who may modify or discard any proposed band (DPA 12.4). Every assessment carries the teacher's written observation and the signature of the tutor or the management.
2.2. Kluppy staff neither issue nor validate student assessments. Support accounts and assisted sessions cannot sign.
3. Limit of use
3.1. The School shall not use the reports as the sole or main basis of a student's official assessment or of decisions that significantly affect the student (B2B Terms, §9.2; DPA 12.5).
3.2. The School sets and documents the weight of the keyboard-writing block within the subject in the module settings. The tool requires it as a mandatory parameter, rejects 100 % and, above 50 %, records the express confirmation of whoever sets it.
4. Documented instruction of the Controller (Art. 28(3)(a) GDPR)
4.1. By accepting these terms, the School, as Controller, instructs Kluppy to process on its behalf, for the purpose described in clause 1, the data listed in Annex I of the DPA relating to the module: measurements from the common test and from practice, classroom notes written by its teachers, signed assessments and reference cut-points.
4.2. Processing is limited to the students of the groups designated by the School, is retained for the duration of the engagement and one hundred and eighty days thereafter, and is erased at the School's request in accordance with Art. 17 GDPR and the module's retention policy.
4.3. This instruction is documented by the acceptance (clause 8) and forms part of the instructions under the DPA.
5. Obligations of the School
5.1. Inform students and their legal representatives of the activation of the module before the first report (DPA §14(e)), and record that fact in the module settings. Without that record no bands are issued.
5.2. Assign each teacher their groups on the platform. A teacher with no assigned groups neither sees nor signs any student.
5.3. Keep the staff with signing permission up to date and notify Kluppy of departures.
5.4. Not pass on to third parties or to report cards a band without the level reached and the volume of practice that accompany it, nor without the legal notice shown on each report.
6. Reference cut-points
6.1. The cut-points that delimit the bands are provisional, are set together with the School on the actual distribution of its own students, are labelled as such and are versioned: a later change creates a new version and does not alter assessments already issued.
6.2. Without the School's written confirmation of the cut-points and of the correspondence table with its report card, no band is issued.
7. Traceability
7.1. Issued assessments, the evidence they were signed on and the cut-points applied are recorded immutably (DPA 12.7). On request, Kluppy will provide the School with the explanation of the calculation of a specific band so that it can handle the exercise of data-subject rights (DPA 12.4).
8. Acceptance, evidence and revocation
8.1. These terms are accepted by a user with the School management role on the platform, who declares having the authority to bind the School.
8.2. Kluppy records the acceptance with the version of the text, server date and time, user and IP address, and sends an email confirmation to the accepting user with a link to the full text. That record is the evidence of the instruction under clause 4.
8.3. The School may revoke the instruction by deactivating the module, without effect on reports already issued, which are retained under clause 4.2.
8.4. Any change to these terms requires a new acceptance of the current version before new reports are issued.
9. Price and invoicing
9.1. The module is an optional service of the School Plan. Its list price is €4.95 per student and school year, VAT not included, applied to the number of student licences contracted by the School, regardless of the number of students assessed or reports issued.
9.2. It is invoiced together with the licences and shares their expiry date. If the module is activated after the licence period has started, the proportional part corresponding to the full months remaining until that expiry is invoiced; licences added during the period incorporate the module in the same proportion.
9.3. The price applicable to each School is the one stated in the accepted commercial offer, which may establish discounts, a different price or the inclusion of the module free of charge for a given period. In the absence of an express mention in the offer, the list price of clause 9.1 applies.
9.4. Kluppy may update the list price by notifying the School at least thirty days before the renewal of the licences; the new price applies from that renewal. VAT and invoicing are governed by the B2B Terms of Service.
9.5. Deactivation of the module by the School before the expiry date (clause 8.3) does not entitle it to a refund of the period already invoiced.
10. Precedence
These terms supplement the B2B Terms of Service and the DPA. In the event of conflict on data protection the DPA prevails; in all other matters, these terms.
Available in Spanish, Basque and English. In case of discrepancy between versions, the Spanish version prevails.