Data protectionLast reviewed: March 2026Next review due: September 2026

GDPR compliance

This page explains how The Responsible AI Center processes personal data in connection with the ALMA platform, in compliance with Regulation (EU) 2016/679 (the General Data Protection Regulation).

Our commitment: ALMA is designed with data minimisation and privacy by design as core principles. We collect only what is strictly necessary to provide the service, we store it securely within the EU, and we never sell your data to third parties.

Who we are

ALMA is operated by The Responsible AI Center (trading as TRAC), a consultancy registered in Belgium. The Responsible AI Center acts as the data controller for all personal data processed through the ALMA platform.

For any data protection enquiries, please contact us at [email protected].

What personal data we collect

ALMA collects and processes the following categories of personal data, depending on how you use the platform:

CategoryExamplesPurpose
Account dataName, work email address, job title, organisationAccount creation, authentication, and communication
Assessment dataPsychometric responses, dimension scores, readiness indicatorsGenerating your AI literacy diagnostic report
Usage dataPage views, feature interactions, session durationPlatform improvement and security monitoring
Technical dataIP address, browser type, device typeSecurity, fraud prevention, and service delivery

We do not collect or process any special categories of personal data (sensitive data) as defined under Article 9 GDPR, such as health data, biometric data, or data revealing racial or ethnic origin.

Our lawful basis for processing

We rely on the following lawful bases under Article 6 GDPR for processing your personal data:

Contract (Art. 6(1)(b))

Processing your account and assessment data is necessary to provide the ALMA service you have requested.

Legitimate interests (Art. 6(1)(f))

We process usage and technical data to improve platform security, prevent fraud, and enhance the user experience. Our interests do not override your rights.

Consent (Art. 6(1)(a))

Where we send optional communications such as regulatory update newsletters, we rely on your explicit consent, which you may withdraw at any time.

Legal obligation (Art. 6(1)(c))

We may process data where required by applicable law, including EU AI Act Article 4 compliance documentation obligations.

How long we keep your data

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law.

Account dataFor the duration of your account, plus 12 months after account closure
Assessment resultsFor the duration of your account, plus 12 months after account closure
Usage logs90 days, then anonymised for aggregate analytics
Security and audit logs12 months
Consent records3 years from the date of consent
Your rights under GDPR

Under the GDPR, you have the following rights with respect to your personal data. To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days.

Right of access (Art. 15)

Request a copy of the personal data we hold about you.

Right to rectification (Art. 16)

Request correction of inaccurate or incomplete data.

Right to erasure (Art. 17)

Request deletion of your data where there is no compelling reason to continue processing.

Right to restriction (Art. 18)

Request that we restrict processing of your data in certain circumstances.

Right to portability (Art. 20)

Receive your data in a structured, machine-readable format.

Right to object (Art. 21)

Object to processing based on legitimate interests, including profiling.

Right to withdraw consent

Withdraw consent at any time where processing is based on consent.

Right to lodge a complaint

Lodge a complaint with your national data protection authority.

If you are based in Belgium, you may also lodge a complaint with the Autorité de la protection des données / Gegevensbeschermingsautoriteit (APD/GBA) , the Belgian data protection authority.

Who we share data with

We do not sell your personal data. We share data only with trusted third-party processors who provide infrastructure and services necessary to operate ALMA, and only under strict data processing agreements (DPAs) compliant with Article 28 GDPR.

Cloud infrastructure providerHosting, database, and storage servicesEU / EEA
Authentication providerSecure sign-in and session managementEU / EEA
Email delivery providerTransactional emails (account notifications)EU / EEA
Analytics providerAnonymised usage analytics for platform improvementEU / EEA

We do not transfer personal data outside the European Economic Area (EEA) without appropriate safeguards in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission.

How we protect your data

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration, in accordance with Article 32 GDPR. These measures include:

Encryption of data in transit (TLS 1.2+) and at rest
Role-based access controls limiting data access to authorised personnel
Regular security assessments and vulnerability testing
Audit logging of access to personal data
Incident response procedures with 72-hour breach notification capability
Data minimisation — we collect only what is strictly necessary
Cookies and tracking

ALMA uses a minimal set of cookies strictly necessary for the platform to function. We do not use advertising cookies or third-party tracking cookies.

Session cookieEssential

Maintains your authenticated session · Session (expires on browser close)

CSRF tokenEssential

Protects against cross-site request forgery attacks · Session

Analytics cookieOptional

Anonymised page view counting for platform improvement · 12 months

Contact and complaints

For any questions about this GDPR compliance statement, to exercise your data subject rights, or to raise a data protection concern, please contact:

The Responsible AI Center

Data protection enquiries

[email protected]

If you are not satisfied with our response, you have the right to lodge a complaint with the supervisory authority in your EU member state. As The Responsible AI Center is registered in Belgium, our lead supervisory authority is the Autorité de la protection des données / Gegevensbeschermingsautoriteit (APD/GBA) .