GDPR

Just Understanding Data Ltd is a private limited company registered in England and Wales under company number 12472031, with registered office at 68, Kings Ride, Penn, High Wycombe, Buckinghamshire, HP10 8BP. It is the data controller for personal data processed through tracelearn.app. For anything in this policy, contact [email protected].

Children never sign themselves up. A parent or tutor creates and controls every child account, and we deliberately collect the minimum a child account needs:

• A display name (this can be a first name or a nickname - it does not need to be a real name).
• A school year group, so practice is set at the right level.
• An avatar, username, and PIN for logging in - no child email address or phone number, ever.
• Learning activity: assignments, answers, scores, attempts, topic progress, session timing, and rewards.

We do not show children advertising, do not market to them, and do not use their data for unrelated profiling. We use learning data to deliver the service a parent or tutor set up, provide feedback and progress reports to linked adults, support safeguarding and service security, and improve learning quality in a tightly scoped way. For improvement work, we use data that is aggregated, pseudonymised, or otherwise minimised where practical. Child learning data is not sent to public-site Google Analytics. The responsible adult can rename a profile or ask us to delete it, subject to limited legal or security retention duties.

The UK Information Commissioner's Children's code guidance informs our privacy-by-design approach.

• Account data: name, email address, and password (stored hashed) for parents and tutors.
• Billing data: subscription status and payment records. Card details are handled by Stripe; we never see or store card numbers.
• Service records: emails we have sent you, support conversations, and technical logs kept for security.
• Public-site analytics: controlled page and navigation events collected by Google Analytics on public marketing pages, without learner activity or direct identifiers.
• Adult campaign attribution: allowlisted click IDs, UTM values, referrer host, landing path, and an opaque first-party key that can link a campaign visit to parent or tutor activation and the first paid subscription.

• Contract: creating and administering an adult account, providing the requested subscription and support, and processing adult billing.
• Legitimate interests in the requested educational service: delivering assignments and practice to a linked child, scoring work, maintaining topic progress, and preparing parent or tutor reports. We balance this against the child's rights and use protective defaults and data minimisation.
• Legitimate interests in safety and quality: safeguarding users, securing accounts, preventing fraud and abuse, fixing errors, measuring reliability, and improving the child-safe learning service with minimised data.
• Legitimate interests in adult acquisition measurement: understanding which public pages and campaigns lead to parent or tutor activation and a first paid subscription, with click data limited to allowlisted fields and kept separately from learner data.
• Consent: adult marketing emails where consent is the appropriate basis. Consent can be withdrawn, and marketing messages include an unsubscribe control.
• Legal obligation: keeping financial records we are required to keep.

We use service providers for specific jobs: Stripe for adult checkout and payments, Resend for account and service email, Cloudflare for public web hosting and Turnstile anti-abuse checks, Google Cloud for infrastructure and database hosting, Google Analytics for controlled public-site events, and error-monitoring services for technical fault context. Where configured, Google Ads or Microsoft Advertising can receive a matching click identifier and adult commercial conversion details. Learner data is excluded. Where a provider processes data outside the UK, we use an applicable adequacy regulation or approved contractual safeguards where the law requires them. We do not sell personal data.

Adult accounts, child profiles, and core learning records are kept while needed to provide the service and preserve requested progress history. Our current automated schedule keeps raw trace and session events for 90 days, learning decision logs for 180 days, and result summaries and mastery snapshots for up to 1,095 days. Raw campaign touch records are kept for up to 90 days. If you ask us to delete an account, we delete or anonymise personal data that is no longer needed, keeping only limited records required for billing, security, disputes, or another legal duty.

Under UK GDPR you can ask us to:

• Give you a copy of the personal data we hold about you or your child (access and portability).
• Correct inaccurate data (rectification).
• Delete data (erasure) - including a full account and all child profiles.
• Restrict or object to processing, and withdraw consent for marketing at any time.

Email [email protected] and we will normally respond within one month, unless UK GDPR permits an extension. You also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk.

See our Privacy Policy, Cookie Policy, and Safeguarding page.