Important Notice for Parents and Guardians: Vocab 9+ is designed for children ages 9–12 preparing for the 11 Plus entrance examination. We are committed to protecting your child's privacy and complying with the Children's Online Privacy Protection Act (COPPA), UK GDPR, and Apple's App Store Guidelines for Kids.
1 About This App
Vocab 9+ is a vocabulary learning mobile application developed and published by Capital Technologies Ltd (trading as TutorsElevenPlus), available on the Apple App Store.
App Purpose: Educational vocabulary building for students preparing for the 11 Plus entrance examination.
Target Audience: Students ages 9–12, used under parental supervision.
2 Information We Collect from Children
We collect minimal information necessary to provide our educational services:
2.1 Account Information
- Name: To personalise the learning experience
- Age: To provide age-appropriate content
- Email address: For account recovery and parental communication
- Password: Encrypted and stored securely for account access
2.2 Learning Data
- Vocabulary words learned and progress
- Quiz scores and test results
- Learning statistics and achievements
- Time spent on learning activities
2.3 Technical Information
- Device type (iPhone / iPad)
- Operating system version
- App version and crash reports
- Push notification token (for notifications)
We DO NOT collect: Location data, photos, contacts, phone numbers, advertising identifiers, or any other sensitive personal information from children.
3 How We Use Children's Information
We use the collected information solely for the following purposes:
- Providing educational vocabulary learning services
- Tracking learning progress and achievements
- Personalising the learning experience
- Sending important app notifications (with parental consent)
- Improving app functionality and fixing technical issues
- Ensuring account security
We will NEVER:
- Sell or rent children's information to third parties
- Show personalised advertisements to children
- Use behavioural tracking or profiling
- Share data with advertisers or marketing companies
- Allow children to publicly disclose personal information
4 Parental Consent
In compliance with COPPA and Apple's Guidelines for Apps Made for Kids, we require verifiable parental consent before collecting any personal information from children under 13.
4.1 How Parents Provide Consent
When a child attempts to create an account, parents must:
- Create the account on behalf of their child using a parent email address
- Verify their email address through a confirmation link
- Complete the account activation process
4.2 Parental Rights
Parents have the right to:
- Review their child's personal information
- Request deletion of their child's information
- Refuse further collection or use of their child's information
- Request a copy of their child's data
5 Data Sharing and Third Parties
We use the following trusted service providers to operate our app:
5.1 Apple Services
- Purpose: App distribution, push notifications, and crash analytics
- Data Shared: Basic device and crash information
- Privacy Policy: apple.com/legal/privacy
5.2 Our Backend Server
- Purpose: Storing learning data and user accounts
- Location: Secure servers in the United Kingdom
- Security: Encrypted connections (HTTPS/SSL)
No Advertising Networks: We do not use advertising networks or show ads to children. We do not collect advertising identifiers (IDFA) from children's devices.
6 Data Security
We implement industry-standard security measures to protect children's information:
- Encryption: All data is encrypted in transit (SSL/TLS) and at rest
- Password Protection: Passwords are hashed using secure algorithms
- Access Control: Only authorised personnel can access user data
- Regular Audits: We regularly review our security practices
- Secure Servers: Data stored on protected servers with firewalls
While we use best practices to protect data, no internet transmission is 100% secure. We cannot guarantee absolute security but work diligently to maintain the highest standards.
7 Data Retention
We retain children's information for as long as the account is active and for up to 30 days after account deletion to allow for account recovery.
Automatic Deletion
- Inactive accounts (no login for 2 years) may be automatically deleted
- Parents will be notified via email before automatic deletion
- Parents can request immediate deletion at any time
8 Children's Rights Under COPPA
Under the Children's Online Privacy Protection Act (COPPA), parents have specific rights:
- Review the personal information collected from their child
- Direct us to delete their child's personal information
- Refuse to allow further collection of their child's information
To exercise these rights, please contact us using the information provided below.
9 Apple App Store Compliance
This app complies with Apple's App Store Review Guidelines and Guidelines for Apps Made for Kids:
- Designed for children ages 9–12
- No inappropriate content
- No third-party advertising
- No data collection beyond what's necessary
- No external links without parental controls
- COPPA-compliant data practices
- No use of advertising identifiers (IDFA)
- App Tracking Transparency not required (no tracking)
10 International Data Transfers
Your child's data is primarily stored on servers located in the United Kingdom. If data is transferred internationally, we ensure appropriate safeguards are in place to protect the information in accordance with applicable data protection laws.
11 Changes to This Privacy Policy
We may update this privacy policy from time to time to reflect changes in our practices or for legal reasons. When we make significant changes, we will:
- Update the "Last Updated" date at the top of this policy
- Notify parents via email
- Display a prominent notice in the app
- Request renewed consent if required by law
We encourage parents to review this policy periodically.
12 Your Rights (Parents/Guardians)
Under UK data protection laws (UK GDPR) and COPPA, you have the following rights:
- Right to Access: Request a copy of your child's data
- Right to Rectification: Request correction of inaccurate data
- Right to Erasure: Request deletion of your child's data
- Right to Restrict Processing: Limit how we use the data
- Right to Object: Object to certain data processing
- Right to Data Portability: Receive data in a common format
Contact Us — Data Protection
13 How to Delete Your Child's Account
Parents can request account deletion at any time:
- Send an email to contact@tutorselevenplus.co.uk
- Include "Delete Account" in the subject line
- Provide the child's account email address
- We will process the request within 7 business days
- You will receive confirmation when deletion is complete
Alternatively, you can delete the account from within the app settings.
14 Governing Law
This privacy policy is governed by the laws of the United Kingdom and complies with:
- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018
- Children's Online Privacy Protection Act (COPPA) — USA
- Apple App Store Review Guidelines
- Apple Guidelines for Apps Made for Kids
Summary for Parents
Vocab 9+ is committed to protecting your child's privacy. We:
- Collect only essential information for educational purposes
- Never show ads or use tracking for marketing
- Give you full control over your child's data
- Use secure, encrypted storage
- Comply with COPPA, UK GDPR, and Apple's guidelines
- Respond promptly to all privacy requests