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LEGAL

Privacy Policy

Last updated: 17 March 2026

This service is operated by an individual developer based in England and Wales, not by a limited company. Accounts are created by a parent or guardian on behalf of a child. By registering, the parent or guardian confirms they are aged 18 or over and accepts this Privacy Policy.

1. Who We Are

AceLearner is a free educational platform designed to help KS2 pupils in England prepare for SATs examinations. It is created and operated by an individual developer based in England and Wales (the “Operator”).

For the purposes of UK data protection law, the Operator is the Data Controller. To contact us about any privacy matter:

Email: privacy@acelearner.co.uk

2. What Data We Collect

We apply a principle of data minimisation: we collect only what is necessary to operate the service. No payment data is ever collected. The service is free of charge.

Parent or guardian account

  • Email address — used to create and access your account
  • Password — encrypted by our authentication provider before storage; we never have access to your password in readable form (see Section 10)
  • First name — used to personalise your dashboard

Child account (created by the parent)

  • Display name — a nickname entered by the parent; this need not be the child's real name
  • Year group — Year 4, 5, or 6
  • Practice session data — questions answered, scores, topics completed, time spent

Technical data collected automatically

  • Server logs including IP address and browser type, collected by our hosting provider (Vercel) as a standard part of operating any web service

We do not collect location data beyond what is inherent in an IP address. We do not use advertising cookies, tracking pixels, or behavioural profiling technologies of any kind.

3. How We Collect Data

Account data is provided directly by the parent or guardian at registration. Passwords are passed securely over HTTPS and are hashed by Supabase Auth before being stored — we never see or store your password in readable form at any point.

Practice data is generated automatically as the child uses the platform. No data is collected from children directly — all account setup is performed by the parent.

4. Legal Basis for Processing (UK GDPR Article 6)

The table below sets out the legal basis for each category of data we process.

DataPurposeLegal Basis
Parent email and first nameAccount creation, login, service communicationsContract (Article 6(1)(b))
Parent password (hashed)Authentication and account securityContract (Article 6(1)(b))
Child display name and year groupPersonalising the practice experienceContract (Article 6(1)(b))
Practice session dataTracking progress, displaying parent dashboardContract (Article 6(1)(b))
Server logs (IP, browser)Platform security and fault diagnosisLegitimate interests (Article 6(1)(f))
Email address (marketing)Sending optional educational updates, if opted inConsent (Article 6(1)(a))

Where we rely on legitimate interests, we have assessed that our interests (platform security, improving service quality) do not override the rights and freedoms of users, given the minimal nature of the data involved.

We do not carry out automated decision-making or profiling within the meaning of Article 22 UK GDPR.

5. How We Use Your Data

  • To create and maintain your account
  • To authenticate you when you log in
  • To display the child's practice history and progress to the parent
  • To generate practice sessions and record learning outcomes
  • To improve question quality and explanations using aggregated, anonymised insights
  • To send essential service communications (for example, material changes to the platform)
  • To send optional educational updates, if you have explicitly opted in

We do not use personal data for advertising, commercial profiling, or any purpose not listed above.

6. Children's Data and the ICO Children's Code

AceLearner is designed for children aged 7 to 11. We operate in accordance with the ICO's Age Appropriate Design Code (Children's Code). Our approach:

  • All accounts are created and managed by a parent or guardian. Children do not register directly.
  • We collect only the minimum data necessary for the service to function.
  • We do not profile children for advertising or any commercial purpose.
  • We do not share children's data with third parties for marketing.
  • Privacy-protective settings apply by default.
  • We do not use nudge techniques or patterns designed to encourage children to share more data than necessary.

7. Who We Share Data With

We do not sell your data. We share data only with the following infrastructure providers, solely to the extent necessary to operate the platform. Each acts as a data processor on our behalf under a Data Processing Agreement.

ProviderRoleData SharedLocation
Supabase (Supabase Inc.)Database, authentication, and password hashingAll account and session data, hashed passwordsEU – Ireland
Vercel (Vercel Inc.)Website hosting and deliveryServer request logsGlobal CDN (see Section 8)

No other third party receives your personal data. We do not share data with analytics platforms, advertising networks, or data brokers.

8. International Data Transfers

Supabase stores your account and session data in the EU (Ireland). However, one aspect of our infrastructure involves processing outside the UK and EEA:

Vercel's content delivery network: Vercel operates a global CDN, meaning web requests may be routed through servers outside the UK and EEA, including the United States. Vercel relies on Standard Contractual Clauses (SCCs) as the lawful transfer mechanism.

Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place in accordance with UK GDPR Article 46, including reliance on SCCs approved for use under the UK international transfer regime.

9. Data Retention

Data TypeRetention Period
Parent account data (name, email, hashed password)For the duration of the active account, then deleted within 30 days of account closure
Child account data (display name, year group)For the duration of the active account, then deleted within 30 days of account closure
Practice session dataUp to 2 years from date of last login
Server logsUp to 90 days, as retained by Vercel under their standard policy
Anonymised, aggregated dataIndefinitely (no personal data retained)

You may request deletion of your account and all associated personal data at any time by contacting us at privacy@acelearner.co.uk. We will complete deletion within 30 days.

10. Security

We have implemented the following technical safeguards:

  • Passwords are hashed using industry-standard methods (bcrypt) by Supabase Auth before storage. We never store or have access to your password in readable form.
  • All data in transit is encrypted using HTTPS (TLS 1.2 or higher)
  • Database access is controlled by row-level security policies in Supabase
  • No payment data is ever collected or stored

No internet-based service can guarantee absolute security. We strongly advise using a unique password for your AceLearner account that you do not use for banking, email, or other important services. Password reuse across multiple services is a significant security risk that is entirely within your control.

11. Cookies

We use only essential session cookies required to keep you logged in while you use the platform. We do not use advertising cookies, analytics cookies, or any third-party tracking technologies. No cookie consent banner is required because we do not use non-essential cookies. You may disable cookies in your browser settings, but doing so will prevent you from logging in.

12. Your Rights Under UK GDPR

As the parent or guardian who created the account, you have the following rights. To exercise any of them, email privacy@acelearner.co.uk. We will respond within 30 days.

RightWhat it means in practice
AccessRequest a copy of all personal data we hold about you and your child
RectificationAsk us to correct inaccurate or incomplete data
ErasureAsk us to delete your account and all associated personal data
RestrictionAsk us to pause processing while a dispute or correction request is resolved
PortabilityReceive your data in a machine-readable format (CSV or JSON)
ObjectObject to processing based on legitimate interests
Withdraw consentWithdraw consent for marketing emails at any time, without affecting any other processing
No automated decisionsWe confirm that no automated decision-making under Article 22 is applied to any user on this platform

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

  • Website: ico.org.uk
  • Telephone: 0303 123 1113

13. Changes to This Policy

We will update this policy when our data practices change or when required by law. Material changes will be communicated by email or by a prominent notice on the platform at least 14 days before they take effect. The “Last updated” date at the top of this document always reflects the current version.

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