NAGchatPilot information
Terms, privacy and AI
Plain-language information about this pilot: what AI does, how accounts and data work, and what still needs verification.
Operator and legal status
NAGchat is a developer-operated pilot hosted on the developer’s PC in Denmark, not a school-operated or independently certified service. The School and personal Chat areas are separate products within this pilot.
- Legal operator
- Magnus Clausen
- Business/service address
- Gustav Adolphsvej 17, 2800 Lyngby, Denmark
- CVR number
- Registration status not supplied; no number is asserted.
- Privacy and support email
- Magn109d@g.nagym.dk
The operator supplied these public contact details on 29 October 2026. Supplier agreements, risk assessments and legal review remain separate requirements. This page does not certify compliance with all Danish laws.
Privacy and data use
Different accounts, different responsibilities
Personal Chat has independent accounts, conversations, files and memories. A matching email address does not link it to a school account. Magnus Clausen is the operator and controller for personal Chat; the final lawful-basis assessment is still outstanding.
For school-directed use, the school must determine purposes, legal basis and permitted use, and the operator’s processor role must be documented in an Article 28 agreement. The school must give pupils and teachers its own clear information. Merely choosing a school or accepting pilot terms does not establish that agreement or provide the school’s legal basis.
What is processed and why
Account name, email, password verifier or school-login identifier, role and settings support sign-in and account management. Sessions, IP addresses, browser information, security events and usage/cost records support security, abuse prevention and service limits. The personal signup audit records the adult declaration and acknowledged terms version, not a date of birth. Email addresses are not verified.
Messages, AI answers, uploaded documents/images, extracted text, folders and saved preferences are processed to answer requests and keep your history. Relevant profile details, instructions, memories and document excerpts can be included in AI requests. Optional search sends an AI-written query to the configured search provider; it can contain personal information if present in the query.
Personalisation can learn short preferences/facts from recent messages and use saved notes or relevant excerpts of your own earlier chats. School quizzes can also generate learning/progress information. Manage memory in Settings. Derived notes are not guaranteed to be correct; deleting one conversation is not the same as deleting every independently saved memory.
In personal Chat, an answer that took several steps (for example search, compare, search again) can be used to write a general how-to for that kind of task, which other Chat users' answers may then follow. The request and the steps go to Mistral to write it; plain code refuses a text with links, long numbers, or names and places from your messages, and nothing is used until the operator has reviewed the text. The library stores no text of yours and does not say who contributed; that you counted towards a skill is stored with your account and deleted with it. Settings → Memory → “Help build NAGchat's skills” turns this off.
In personal Chat, NAGchat also saves lasting facts about you without being asked – for example where you live (including an address you write), your work or study, family and pets, interests, favourites and things you own – and shows each one with Undo. Health, religion, political views, sexuality, ethnicity, union membership, money and criminal matters are never saved on their own: NAGchat asks “Remember this?” and saves only if you tap Save. School accounts do not get this.
Normal teacher and administrator interfaces do not provide access to other users’ private chats. School teachers can see named activity counts and assignment-start status. The operator has privileged technical administration of the database; this is not a claim that the operator is technically unable to access data. A feedback report includes a chat snapshot only if you explicitly choose to share it; platform operators can then read that shared copy.
Chats, answers, files, memories and similar private content are encrypted in the database with a key per user, so database dumps and backups do not contain readable text, and deleting an account deletes its key. The master key is on the same server, so this protects against database access and leaked backups, not against the operator. Checked on 19 October 2026 by 66 automated privacy checks on a test database.
Lawful basis: outstanding approval
Necessary personal account and request processing needs a documented Article 6 basis, for example performance of a contract where objectively necessary. Security processing may require a documented legitimate-interest balancing assessment. Optional purposes need their own assessment or valid specific consent where required. These are proposed grounds for review, not a claim that assessments have been completed. School-directed processing needs the school’s own basis; public-task processing cannot simply be replaced with a generic consent checkbox.
Retention and deletion
Current code defaults: chats after 90 days without activity; ordinary one-off attachments after 30 days or earlier expiry; quizzes after 90 days; podcasts under the shorter content limit. Organisation policies can change these limits. Files saved in folders are excluded from automatic attachment expiry and remain until deleted with the file, folder or account.
Accounts, saved memories and preferences do not have a general inactivity expiry in the current code. Usage and audit records do not currently have a configured automatic retention deadline. A justified schedule and deletion process must be decided; indefinite storage is not presented as legally approved. Actual backup locations, expiry and deletion-after-restore procedures have not been confirmed.
Providers and international data flows
The application and database run on the developer’s PC in Denmark. AI chat, relevant document text and OCR requests use Mistral AI’s European API endpoint; when Mistral cannot answer a chat message, Melious (below) answers it instead. Routing to that endpoint is not by itself proof of GDPR compliance. Zero Data Retention is confirmed as enabled for the organisation (Mistral support approval and console, 15 October 2026; console checked again 19 October 2026). It applies to stateless APIs (chat completion, embeddings, classifiers and OCR), which are the endpoints and models NAGchat uses, and not to stateful APIs (agents, batch, files, conversations, libraries) or Labs models, which NAGchat does not use. In the same console, the organisation setting that lets Mistral train its models on API calls is off, and Labs models (which Mistral may train on regardless of that setting) are not enabled (19 October 2026). Mistral may still process metadata for billing and security monitoring.
- Mistral AI (France): receives request context for AI inference, document/image OCR and enabled AI features.
- Cloudflare (US company): provides the public HTTPS connection and tunnel, terminates TLS and can process network metadata and traffic. The service is not end-to-end encrypted against Cloudflare.
- Staan (Qwant/Ecosia, France): receives search queries when web search is used, in School and in personal Chat. Staan keeps the query text, time and market for 25 months, and a query its own index cannot answer can be passed to a US search provider (Staan's written answer, 20 October 2026). Pages opened by the server receive server-side requests; following external links sends your browser to that external website.
- jsDelivr and cdnjs/Cloudflare: some chat rendering, maths and document-viewer libraries are downloaded by your browser. Their operators receive connection metadata such as your IP address. Browser document OCR is designed to run locally, but uses externally downloaded code/models. This legal page loads no external libraries or fonts.
- School identity providers (for example Microsoft Entra): handle school SSO under the school’s setup. Private podcast speech, when enabled, uses the configured operator-managed voice server; unapproved voice evaluation is not general public access.
- Weather, in personal Chat only (MET Norway, Norway; Open-Meteo for place names; Photon by komoot, Germany): when you ask about the weather, a place name you type, or your device’s location rounded to about 1 km, is sent to find the forecast and the town’s name. NAGchat does not store the location.
- Melious (Germany): an EU AI gateway (GLM 5.3 Flash and DeepSeek V4.1 Flash). It answers chat messages for every account, students included, when Mistral cannot answer them (out of credit, key refused, overloaded or unreachable); the answer then shows that model’s name. It also answers for accounts the operator has added to model evaluation, after the account holder picks a test model in Settings. Melious wrote on 22 October 2026 that inference stays in the EU/EEA (DeepSeek on its own servers in Finland; GLM on its servers in Finland or at TensorX in Ireland), that it logs no prompt or answer content, and that no provider trains on the traffic. A signed processing agreement is not yet in place.
EU AI processing does not mean every connection or supplier is confined to the EU. Processor/subprocessor contracts, exact locations and any Chapter V transfer basis must be confirmed. A supplier’s possible participation in a transfer framework is not a substitute for checking the actual service and contract. No verified no-transfer guarantee is made here, and the Zero Data Retention setting covers only the Mistral account, not other suppliers.
Your rights and complaints
Depending on the conditions in GDPR, you can request access, rectification, erasure, restriction and data portability, and object to relevant processing. Where processing relies on consent, you may withdraw it without affecting the lawfulness of earlier processing. A request normally requires a response within one month; statutory extensions and exceptions must be explained.
You can delete individual chats/files/memories in the app and withdraw feedback. Settings → Your data offers a chat/memory/podcast export when enabled. That download is not a complete Article 15 response: original files, all profile/settings data and technical records are not all included. A disabled download button does not remove your statutory rights.
School users should contact their school’s controller or data-protection contact. A school account is deleted by the school’s administrator. A personal Chat account can be deleted by its owner in the iPhone app (Settings → Your data). Personal users can send privacy and support requests to the operator’s email in the Operator and legal status section. Never include your password, verification code or unnecessary sensitive information in a request.
You may complain to the Danish Data Protection Agency. Datatilsynet.
Pilot terms and AI disclaimer
You are interacting with AI
NAGchat produces AI-generated responses, not messages from a human adviser. Responses can be wrong, incomplete, biased or out of date, including calculations and citations. Check important claims against reliable original sources. Maths checks do not verify every assumption; Maple examples are not executed in Maple.
Do not use NAGchat as your sole basis for medical, legal, financial or safety-critical decisions, or as an emergency service. Consult an appropriate professional. For immediate danger in Denmark, call 112.
Personal Chat: adult pilot
New personal registrations are restricted to users aged 18 or over. You must truthfully confirm that age and acknowledge these dated pilot terms. We do not collect a date of birth or verify identity from that declaration. This is a service policy, not a claim that Danish law universally requires an 18+ limit for chatbots. School access remains separate.
New personal accounts have about USD 1 of total AI allowance until approved by a Chat administrator; organisation budgets and rate limits also apply. The allowance is a service limit, not a charge to your payment card. This pilot has no checkout or subscription purchase flow. Payment terms and any applicable consumer information must be supplied before any paid offer is introduced.
Use and rights in content
Use the service lawfully. Do not upload passwords, access tokens, CPR numbers, confidential third-party data or material you have no right to use. Avoid health and other sensitive personal information. Do not attempt to access other accounts, bypass restrictions or share illegal material. These rules do not replace the operator’s data-protection duties.
You retain the rights you have in your input; no transfer of your ownership is claimed. Processing by the service and its providers is limited to the requested functions and the applicable agreements. AI output may not be original, exclusive, copyright-protected or free of third-party rights. Check rights before reusing or publishing it.
Fair limitations, not a waiver
This is a pilot: availability, uninterrupted operation and particular answers are not guaranteed. Changes may affect access, but these terms do not create a right to arbitrarily disregard statutory obligations. Important contractual changes must be communicated before they are relied on; this version is not a retroactive agreement by existing users.
Nothing here excludes liability where it cannot lawfully be excluded, removes mandatory Danish/EU consumer rights, waives GDPR rights or prevents a complaint to a competent authority or court. An AI warning explains limitations; it is not a blanket exemption from responsibility. Accepting terms is not blanket consent to personal-data processing, model training or tracking.
For schools and teachers
A school must approve the concrete processing before school-directed use: establish the lawful basis, provide pupil/teacher information, sign and supervise the processor agreement, review subprocessors/transfers and assess security and any need for a DPIA. No completed school agreement, DPIA or regulatory approval is asserted on this page.
School teachers can request a group summary based on at least three pupils’ questions from the last 14 days. Questions are processed server-side, including through AI; names are scrubbed and the summary must avoid quotes or individuals. A small group and distinctive wording can still identify a pupil. This is not guaranteed irreversible anonymisation and must be assessed in the school’s risk analysis. It does not operate in personal Chat.
Learning advice, quiz results and subject summaries must not be treated as validated grades, admissions decisions or disciplinary evidence. The intended use and learning-evaluation functions need a documented AI Act classification; a human in the loop or a disclaimer alone does not remove high-risk status if it otherwise applies. Staff operating the system need appropriate AI literacy.
Official sources and outstanding work
Outstanding operator work: document lawful purposes/bases; confirm supplier agreements, locations and transfer safeguards; decide retention/backups; make rights and complaints handling operational; complete school risk/DPIA work; classify AI Act, DSA and accessibility duties for the actual service. No public “fully compliant” claim should be made before these gaps are resolved.
- GDPR — articles 5–9, 12–22, 28, 32, 35 and Chapter V
- Databeskyttelsesloven — § 6 (Danish consent-age rule)
- DIGST / Datatilsynet — cookies and similar technologies
- Datatilsynet — controller and processor roles
- Datatilsynet — DPIA
- Forbrugerombudsmanden — e-commerce information duties
- European Commission — AI transparency guidance
The 15-year Danish threshold concerns a child’s own consent where Article 6(1)(a) is used for an online service. It is not a general licence for every use of children’s data. Our new personal-account policy is stricter at 18+.