Vocab 11+ Privacy Policy - Protecting Children's Privacy

Last Updated: January 2025 | Effective Date: January 2025

Important Notice for Parents and Guardians: Vocab 11+ 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) and Google Play's Families Policy.

1. About This App

Vocab 11+ is a vocabulary learning mobile application developed and published by Capital Technologies Ltd (trading as TutorsElevenPlus), available on the Google Play 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 personalize 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 (Android phone/tablet)
Operating system version
App version and crash reports
Firebase Cloud Messaging token (for notifications)

We DO NOT collect: Location data, photos, contacts, phone numbers, 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
Personalizing 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 personalized advertisements to children
Use behavioral tracking or profiling
Share data with advertisers or marketing companies
Allow children to publicly disclose personal information

4. Parental Consent

In compliance with COPPA, 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 Firebase (Google)

Purpose: Authentication, database, and push notifications
Data Shared: Account information, learning progress
Privacy Policy: firebase.google.com/support/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 IDs 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 authorized 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. Google Play Families Policy Compliance

This app complies with Google Play's Families Policy requirements:

✓ 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

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 (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

For any questions, concerns, or requests regarding your child's privacy or data:

Email: contact@tutorselevenplus.co.uk

Subject Line: "Vocab 11+ Privacy Request"

Company: Capital Technologies Ltd (trading as TutorsElevenPlus)

Response Time: We will respond to all privacy requests within 30 days

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
Google Play Families Policy

Summary for Parents

Vocab 11+ 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 and GDPR regulations
✓ Respond promptly to all privacy requests