Privacy

1. Introduction

This Privacy Policy explains how Edly ("we," "us," or "our") collects, uses, and protects your personal information when you use our AI-powered educational mobile application ("App") available on iOS and Android platforms in the United Kingdom.

We are committed to protecting your privacy and complying with UK data protection laws, including the UK Data Protection Act 2018, UK GDPR, and the Age Appropriate Design Code (Children's Code).

2. Who We Are

3. Information We Collect

3.1 Personal Information You Provide

• Account Information: Name, email address, age verification details
• Educational Profile: Academic level, subjects of interest, learning preferences
• Parental Consent: For users under 18, we collect parental consent records
• Support Communications: Messages sent to our customer support team

3.2 Information Automatically Collected

• Usage Data: App features used, time spent, learning progress, assessment scores
• Device Information: Device type, operating system, app version, device identifiers
• Technical Data: IP address (anonymized for users under 18), crash reports, performance metrics
• AI Interaction Data: Questions generated, topics selected, learning patterns

3.3 Information We Do NOT Collect from Children

• Location Data: We do not collect precise location information from users under 18
• Behavioral Advertising Data: No tracking for marketing purposes for minors
• Personal Photos/Videos: Children cannot upload or share multimedia content
• Social Information: No social networking features for users under 18

4. How We Use Your Information

4.1 Educational Purposes

• Generate personalized AI-powered question papers and assessments
• Track learning progress and provide educational recommendations
• Adapt content difficulty to individual learning levels
• Provide usage statistics to parents/guardians

4.2 App Functionality

• Create and maintain user accounts
• Process in-app purchases and subscriptions
• Provide customer support and respond to inquiries
• Send important updates about the App

4.3 Safety and Compliance

• Verify age and obtain parental consent where required
• Monitor content for child safety and appropriateness
• Comply with legal obligations and regulatory requirements
• Prevent fraud, abuse, and unauthorized access

4.4 AI Content Improvement

• Analyze usage patterns to improve AI-generated content quality
• Identify and correct errors in educational material
• Enhance curriculum alignment and educational effectiveness

5. Legal Basis for Processing (UK GDPR)

5.1 For Adult Users (18+)

• Contract Performance: To provide educational services as outlined in our Terms
• Legitimate Interest: To improve our services and ensure platform security

5.2 For Children (Under 18)

• Parental Consent: Primary legal basis for processing children's personal data
• Vital Interests: For child safety and protection purposes
• Legal Obligation: To comply with UK child protection requirements

6. Child-Specific Privacy Protections

6.1 Age-Appropriate Design

• Data minimization: We collect only data necessary for educational functionality
• Default high privacy settings for all users under 18
• No behavioral advertising or profiling of children
• Built-in usage time controls and break reminders

6.2 Parental Rights and Controls

• Access: Parents can request copies of their child's data
• Correction: Parents can correct inaccurate information
• Deletion: Parents can request deletion of their child's account and data
• Objection: Parents can object to certain data processing activities
• Withdrawal: Parents can withdraw consent at any time

6.3 Enhanced Safety Measures

• All AI-generated content is filtered for age-appropriateness
• No direct communication features between users under 18
• Immediate reporting mechanisms for safety concerns
• Regular safety audits and risk assessments

7. Data Sharing and Disclosure

7.1 We Do NOT Sell Personal Data

We never sell, rent, or trade personal information to third parties for marketing purposes.

7.2 Limited Sharing Scenarios

• App Store Partners: Apple App Store and Google Play Store for payment processing
• Technical Service Providers: Cloud hosting, analytics, and security services (with strict data processing agreements)
• Legal Requirements: When required by UK law or court order
• Child Safety: With appropriate authorities if child protection concerns arise

7.3 International Transfers

• Data is primarily processed within the UK
• Any international transfers comply with UK GDPR adequacy decisions
• Appropriate safeguards are in place for all data transfers

8. Data Retention

8.1 Account Data

• Active Accounts: Retained while account remains active
• Inactive Accounts: Deleted after 2 years of inactivity (1 year for child accounts)
• Deleted Accounts: Data permanently deleted within 30 days of account deletion

8.2 Child-Specific Retention

• Children's data is retained for the minimum period necessary
• Automatic deletion when child reaches 18 (unless they choose to maintain adult account)
• Parents can request immediate deletion at any time

8.3 Legal Compliance

• Some data may be retained longer to comply with legal obligations
• Safety-related records may be kept for child protection purposes

9. Data Security

9.1 Technical Safeguards

• End-to-end encryption for sensitive data
• Secure cloud infrastructure with regular security updates
• Multi-factor authentication for administrative access
• Regular security audits and penetration testing

9.2 Organizational Measures

• Staff training on data protection and child safety
• Access controls limiting who can view personal data
• Data breach response procedures
• Regular compliance reviews

9.3 Child-Specific Security

• Enhanced security measures for children's accounts
• Additional monitoring for unusual activity
• Immediate alerts for potential safety concerns

10. Your Rights Under UK GDPR

10.1 Individual Rights

• Right to Information: Clear information about data processing
• Right of Access: Request copies of your personal data
• Right to Rectification: Correct inaccurate personal data
• Right to Erasure: Request deletion of personal data
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a portable format
• Right to Object: Object to certain types of processing

10.2 Exercising Your Rights

Contact our Data Protection Officer at mahesh@edly.uk to exercise any of these rights. We will respond within one month of receiving your request.

10.3 Right to Complain

You have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

11. Cookies and Tracking Technologies

11.1 Essential Cookies

We use necessary cookies to ensure the App functions properly and securely.

11.2 Analytics

• Limited analytics to improve app performance
• No behavioral tracking for users under 18
• All analytics data is anonymized

11.3 No Advertising Cookies

We do not use advertising cookies or tracking technologies for marketing purposes, especially for users under 18.

12. Third-Party Services

12.1 App Store Integration

• Apple App Store and Google Play Store for app distribution and payments
• Subject to their respective privacy policies
• We do not control their data practices

12.2 Educational Content Links

• App may contain links to educational resources
• Third-party sites have their own privacy policies
• We are not responsible for third-party privacy practices

13. Changes to This Privacy Policy

13.1 Notification of Changes

• We will notify users of material changes through the App
• Email notification to registered users (and parents for child accounts)
• At least 30 days notice for significant changes affecting children

13.2 Continued Use

Continued use of the App after changes constitutes acceptance of the updated Privacy Policy.

14. Contact Information

15. COMPREHENSIVE LIABILITY LIMITATIONS AND LEGAL DISCLAIMERS

16. Additional UK-Specific Provisions

16.1 Consumer Rights Limitations

While UK Consumer Rights Act 2015 provides certain mandatory protections that cannot be waived, our liability for any statutory consumer rights violations is limited to the maximum extent permitted by law.

16.2 Educational Standards Disclaimer

Our data practices support general compliance with UK National Curriculum standards, but we make no warranties about complete accuracy, current compliance, or educational effectiveness for any specific exam board or qualification.

16.3 Brexit Compliance

Our privacy practices comply with UK data protection requirements independent of EU GDPR obligations. However, changes in UK law may affect service availability or functionality without notice.

16.4 Accessibility

This Privacy Policy is available in accessible formats. If you need assistance accessing this information, please contact us at nataraj@edly.uk.