Privacy notice

This is a draft for review. It is published so you can see how we intend to operate, and it will be finalised before any paid plans launch. Sections marked as placeholders are still being prepared.

1. Who we are

[Placeholder: data controller identity and contact details, including a contact for privacy questions.]

2. Children first

TutorLumi is designed for use by children, so we hold ourselves to the standards of the ICO's Age Appropriate Design Code. In practice that means: we collect the minimum we need, we do not profile children for advertising, there are no ads and no third-party trackers, and parents can follow their child's learning on the service. Parents see summary-level information (progress, strengths, struggles and engagement), not verbatim conversation transcripts; our safety screening alerts parents when something needs them. Children can see what their parent can see of them.

3. What we collect

  • From parents: name, email address, password and multi-factor authentication details, or your social sign-in identity if you use that instead.
  • Optionally, from parents using the 11+ planner: your home postcode, never your full address. It is used for one thing, estimating how far each grammar school is, because distance is the tie-breaker most councils fall back on. We look it up through postcodes.io (Ordnance Survey and ONS open data) from our own server, sending only the postcode and nothing that identifies you or your child. Clear the field and it is deleted.
  • From children: a display name, school year group, and the work they do on the service, including homework photos, conversations with the tutor, quiz results and progress records. No child email addresses or phone numbers.
  • If a homework photo does not scan properly, you or your child can choose to send it to our team. The app then reads the photo again more carefully and corrects what it got wrong, and a person on our team may look at the photo to check the fix, or to fix it themselves when the app cannot. We email you when it is ready or if we need one more photo. Nothing is sent to us this way unless one of you taps to send it.
  • Retention: verbatim tutoring transcripts are removed after 12 months of inactivity (a short session summary is kept in their place); safety screening records are kept for 24 months; and deleting your account removes everything, including uploaded photos.
  • [Placeholder: full data inventory and lawful bases.]

4. Where your data lives

Your family's data is stored in the United Kingdom. Some processing is carried out by carefully chosen service providers. [Placeholder: list of processors, what each receives, and international transfer safeguards for AI processing.]

5. Your rights

You can download your family's data, or delete your whole account, directly from your settings at any time. The download holds what you can see in the app: marks, progress, marking reports and rewards. It leaves out your child's own words, such as their chats with the tutor and their 11+ writing, and the notes written back to them after a practice interview. You also have the usual rights under UK data protection law. [Placeholder: full rights wording, how a child asks for their own copy, and how to complain to the ICO.]