Privacy Policy

1. Our approach

Transformative Minds is used by and for children with special educational needs, so we collect as little personal information as we can and keep it for no longer than we need it.

We never sell personal information, never use children's data for advertising, and never profile children for any purpose other than choosing their next learning step.

2. Information we hold

About adults: name, email address, role (parent, carer, teacher, therapist or school administrator), the school an account belongs to, and account status such as active, disabled or on credit stop.

About children: a first name or nickname chosen by the adult, a chosen avatar and colour, support settings such as larger text, calmer colours, read-aloud prompts or tap-only answers, and their learning activity — questions attempted, answers given, accuracy, timing and skill progress.

About schools: school name, logo, invitation link and join code, number of places purchased, and the rate the school sets for its families.

Technical information needed to run the service securely, such as sign-in events and error reports.

3. Please keep children's records minimal

Only a first name or nickname is needed for a learner. Please do not enter a child's full name, date of birth, address, medical or diagnostic information, or anything else that is not needed for their learning.

Transformative Minds describes support needs in terms of what helps a child learn. It does not record diagnoses.

4. Why we use it, and our lawful basis

To provide the learning service and choose each child's next activity — performance of our contract with the account holder, or the legitimate interests of a school using it for education.

To show progress reports to the adults responsible for a child — the same basis as above.

To manage accounts, seats, payments and credit — contract and our legitimate interest in running the service.

To keep the service safe and working — legitimate interests, and legal obligations where they apply.

To send tips and guidance emails to parents and carers — legitimate interests or your consent, and you can opt out at any time.

5. Schools as data controllers

Where a school sets up an account and enrols families, the school decides how learner information is used within that account and acts as data controller; we act as processor on its instructions. For independent family accounts, we are the controller.

School administrators and app administrators can see the account information and learning activity within their scope so they can support learners and manage accounts.

6. Who can see the information

The adult who created a learner record, staff at the school that learner belongs to where relevant, and our own administrators who support the service.

Our service providers — hosting, database, authentication, email delivery and payment processing — acting only on our instructions and under contract.

Anyone we are legally required to disclose to, or where disclosure is necessary to protect a child from harm.

7. Storage, security and transfers

Information is stored on secure managed infrastructure with access controls, encryption in transit, and record-level rules so an account can only reach its own data.

Some providers may process data outside the UK or EEA. Where that happens we rely on appropriate safeguards such as adequacy decisions or standard contractual clauses.

8. How long we keep it

Learner records and learning activity are kept while the account is open, and deleted or anonymised within 90 days of the account being closed or the learner being removed.

Account and billing records may be kept longer where we must, for example to meet accounting obligations.

9. Your rights

You can ask for a copy of the information we hold, ask us to correct or delete it, object to or restrict how we use it, and ask for it in a portable format. A parent or carer can exercise these rights on behalf of their child.

Where we rely on consent, you can withdraw it at any time. Contact us and we will respond within one month.

If you are not satisfied with our response you can complain to the Information Commissioner's Office at ico.org.uk.

10. Cookies and similar technology

We use only what the service needs to work: keeping you signed in, remembering your settings, and keeping the service secure. We do not use advertising or cross-site tracking cookies.

11. Changes and contact

We will update this policy as the service develops and tell account holders about significant changes.

For any privacy question, or to exercise your rights, contact us at the address published by Transformative Minds.