⚠️ DRAFT — this notice is not yet in force. Items in [brackets] are placeholders awaiting sign-off.

Privacy Notice (parents, guardians & teachers)

Version 2026-07 · Last updated [DATE] · Read the children's version

SumSpark Maths ("SumSpark", "we") is an online maths tutor for children, run by [LEGAL ENTITY TBC — name, company number, registered address], the data controller. Privacy questions: privacy@sumspark.co.uk [mailbox to be confirmed]. You can complain to the ICO (ico.org.uk), but we'd welcome the chance to help first.

The short version

• Your child's account has no email address, no full date of birth, no address and no photo — just a username you choose, a first name, and a school-year band.
• Chats with Max (our AI tutor) are screened for safety both ways, stored so you can review them, and never used to advertise anything.
• We never sell data. We never advertise to children. We never let the AI decide whether your child's answer is right — that's checked by ordinary software.
• Card details go to Stripe, never to us.
• You can see, correct, export or delete your family's data — see "Your rights".

1. What we collect

About you (the adult): name, email, password (stored only as a strong hash), optional Google/Microsoft sign-in identifiers, two-factor secret (encrypted), your subscription plan and Stripe customer reference (not your card), device/session data and IP addresses for security.

About your child: the username and password you set, first/display name, school year and age band (not their birthday), their practice answers and timings, their progress by topic, their conversations with Max, and anything they draw on the working-out pad. If you import rewards from the old SumSpark site, we store those stars/badges too.

Safeguarding records: if a chat message suggests a child may be at risk, or the safety filters flag content, we keep a record of the flagged content and what we did about it. This is the most sensitive data we hold; access to it is restricted and itself logged.

2. Why, and our legal grounds

• Providing the service — contract (with you, the adult).
• Your child's account — your parental consent, recorded per child.
• Safety screening and safeguarding escalation — legitimate interests (child protection), or vital interests in serious cases.
• Progress tracking and topic recommendations — contract; this is the product, and it never makes significant automated decisions about your child.
• Payments — contract and legal obligation (via Stripe).
• Security and audit logs — legitimate interests.
• Marketing — only ever with separate consent.

3. The AI, plainly

Max's replies come from Anthropic's Claude models. Your child's message and recent conversation are sent to Anthropic's API to generate a reply; our contract with them [to be executed before launch] prevents use of these conversations to train their models. System instructions live on our servers; your child's text is treated strictly as content. Every AI exchange is safety-screened before and after, logged, and visible to you. Scored questions and marking never come from the AI.

4. Who else touches data

Only processors working for us — see the current list at sumspark.co.uk/subprocessors. We share data with no one else, unless the law requires it or a child's safety demands it.

5. Where and how long

Data is stored in the UK/EU [production host to be confirmed]. AI requests are processed by Anthropic in the US under UK-approved transfer safeguards [IDTA/Addendum to be executed]. Retention: chat transcripts [12 months] then anonymised; learning history for the life of the account; safeguarding records [6 years]; backups rotate after 14 days; deleted accounts are erased or anonymised within 30 days of your request.

6. Your rights (and your child's)

Access, rectification, erasure, restriction, portability, objection — for your data and, as their parent/guardian, your child's. Older children can exercise rights themselves where they have capacity. Use privacy@sumspark.co.uk or the in-app deletion request; we respond within one month. Reviewing your child's chat history is available to you in-app — and every such access is logged, which your child is told about in their own notice.

7. Changes

We'll tell you by email and in-app before any material change takes effect, and we record which version you accepted.