Privacy Policy
Draft for legal review before launch. Last updated: October 2026.
Kestrel is a learning service for families, operated from the United Kingdom. This policy explains what we collect, why, and the choices you have. Kestrel is designed to comply with UK GDPR and the ICO Age Appropriate Design Code (Children's Code).
Who the account belongs to
Accounts are created and held by a parent or carer aged 18 or over. Children do not create accounts, do not provide an email address and cannot be contacted through Kestrel. A child profile consists only of a first name (or nickname), a school year group and learning progress.
What we collect
- Account data: the parent's email address, used to sign in with a one-time link and to send service emails.
- Learner profiles: first name or nickname, school year group, avatar colour, and any tutor or avatar design choices a child makes (a drawn character, its colour and name, and cartoon avatar options such as hair style or glasses). These are simple drawings, never photographs, and are visible only within your family account.
- Learning data: questions answered, whether they were correct, difficulty, time taken, mastery estimates, streaks, XP and badges. This is what makes Kestrel adaptive and powers the parent dashboard.
- Family topics: titles, notes and questions a parent writes for their own child. They are private to your account and are never shared with other families or used to train any model.
- Billing data: handled by Stripe. We store a Stripe customer reference and subscription status; we never see or store card numbers.
- Technical data: basic server logs (IP address, browser type, timestamps) retained for security for up to 30 days.
What we do not do
- No advertising, no behavioural profiling for marketing, no sale or sharing of data with data brokers.
- No open chat, messaging or public leaderboards. Leagues are limited to the learners within one family account.
- No precise geolocation, camera or microphone access. Read-aloud plays pre-recorded synthetic voices or uses your device's built-in speech synthesis; nothing a child says is ever recorded.
- No conversation between a child and an AI. Where generative AI is used (an optional second explanation of a question a child got wrong, and drafting a family topic from a parent's notes) the request is a single, fixed-purpose call made by our server, contains no child's name or account details, is logged for the parent to review, and the output is checked and, for family topics, approved by the parent before a child sees it.
- No nudge techniques that encourage children to extend use against their interests. Streaks and quests reset gently and never penalise a missed day financially.
Why we process data (lawful bases)
Providing the service you have subscribed to (contract); keeping the service secure and improving curriculum content using aggregated, de-identified statistics (legitimate interests, balanced against children's rights); and sending service emails (contract). We do not rely on a child's consent for any processing.
Where data is stored
Data is hosted on Supabase (database and authentication) in the London (eu-west-2) region and served through Vercel. Stripe processes payments. Optional AI features send the question text or the parent's topic notes to Anthropic (Claude) under its commercial API terms, which do not permit training on that data. Each provider acts as our processor under a data processing agreement.
Retention
Learning data is kept while the account is active. If you delete a learner, their data is deleted within 30 days. If you close the account, all family data is deleted within 30 days except billing records we must keep for tax purposes (6 years). De-identified aggregate statistics (for example, "42% of Year 4 learners find fractions of amounts hard") may be retained.
Your rights
You can access, correct, export or delete your family's data at any time from Settings or by emailing privacy@kestrellearning.co.uk. You also have the right to object, to restrict processing and to complain to the Information Commissioner's Office (ico.org.uk).
Cookies and local storage
Kestrel uses strictly necessary storage only: a sign-in session and a local copy of progress so the app works offline. No analytics or advertising cookies are set.
Contact
Data controller: Trusted Intelligent Systems, trading as Kestrel (registered business details: [TO CONFIRM BEFORE LAUNCH: legal entity name, company number or sole-trader status, and registered address]). Email: privacy@kestrellearning.co.uk.