Privacy Policy
Draft version — not yet reviewed. Last edited: [DATE].
Revision Ninja ("we", "us") is a revision and quiz platform used by schools, teachers, and students. This notice explains what personal data the app collects, why, and what rights you have over it. It applies to teachers, school administrators, and students (including students under 18) who use the site.
1. Who is responsible for your data (data controller)
[PLACEHOLDER — confirm controller relationship with a lawyer before launch.] For pupil data entered by a school (e.g. class rosters), the school is typically the data controller and Revision Ninja acts as a data processor on the school's behalf, under a data processing agreement (see our Terms of Service). For account data created directly by an individual (e.g. a teacher signing up without a school agreement), Revision Ninja acts as the controller.
Data controller contact: [Company legal name — PLACEHOLDER] · [Registered address — PLACEHOLDER] · [privacy@revision-ninja.example — PLACEHOLDER contact address].
2. What data we collect
We collect the following categories of personal data:
- Account data — name, email address, and profile photo, supplied by Google Sign-In when you sign in with a Google account.
- School & class data — for teachers and school admins: the school name and teacher email addresses assigned to it; for students: the class rosters (student email addresses) that a teacher adds to a class group.
- Learning & progress data — lessons completed, quiz answers and scores (including full attempt history), a spaced-repetition revision schedule, streaks, and experience points (XP) earned while using the platform.
- Technical/usage data — last-active timestamp, used to keep account records current.
- Payment data [PLACEHOLDER — confirm before launch if paid courses go live]: where a course requires payment, card and billing details are collected and processed directly by our payment processor, Stripe; we do not store full card numbers ourselves.
3. Why we collect it, and our lawful basis
[PLACEHOLDER — lawful basis must be confirmed per category with a lawyer.] In outline:
- Account and progress data is used to provide the core service — delivering lessons/quizzes, tracking completion and mastery, and showing progress to the student and their teacher. Lawful basis: typically performance of a contract with the school (Article 6(1)(b) UK GDPR) or the school's legitimate interests in providing education, exercised through us as processor.
- School and class roster data is used so teachers can see their students' progress in a gradebook. Lawful basis: as instructed by the school acting as controller.
- Where a student is under 13, additional safeguards under the ICO Children's Code and, where relevant, parental/school consent requirements apply — see Section 5 below. [PLACEHOLDER — confirm age-gating and consent flow with a lawyer; none currently exists in the product.]
4. Who we share data with
We use the following processors/sub-processors to run the service. None of them are permitted to use your data for their own advertising purposes:
- Google Cloud / Firebase (Authentication, Firestore database, Cloud Storage) — hosts all account, roster, and progress data and provides sign-in. Acts as a sub-processor.
- Stripe [PLACEHOLDER — confirm if/when enabled] — processes payment for any paid courses.
We do not currently use any advertising, marketing, or third-party analytics trackers, and we do not sell personal data. [PLACEHOLDER — keep this statement accurate; update it immediately if analytics or advertising tooling is ever added, see Section 6.]
5. Children's data
Many users of this platform are school students under the age of 18, including children under 13. We aim to handle their data in line with the ICO's Age Appropriate Design Code ("Children's Code"): collecting the minimum data needed to run the service, not using children's data for advertising or profiling, and not sharing it with third parties beyond what is needed to provide the service. [PLACEHOLDER — this section is a starting point only; a full Children's Code conformance assessment has NOT been carried out and must be done, with a lawyer, before onboarding real schools.]
6. Cookies & local storage
We do not use advertising or analytics cookies. Signing in uses Google Firebase Authentication, which stores a session token in your browser's local storage/IndexedDB so you stay signed in between visits; the app also caches course and progress data locally so it keeps working briefly if your connection drops. These are strictly necessary for the service to function and are not used for tracking or advertising. [PLACEHOLDER — if analytics, ads, or other non-essential tracking are ever added, this section must be rewritten and a cookie consent banner must be added before those tools are enabled, given our child users.]
7. Data retention
[PLACEHOLDER — no retention schedule currently exists and one must be agreed with a lawyer and with partner schools before launch. In particular: how long do we keep a student's account and progress data after they leave the school, or after a school ends its agreement with us? Draft position: personal data will be deleted or anonymised within [X months — PLACEHOLDER] of an account becoming inactive, or sooner at a school's request.]
8. Your rights
Subject to UK GDPR, you (or, for a child, their parent/guardian or school acting on their behalf) may have the right to access, correct, delete, restrict, or port your personal data, and to object to certain processing. To exercise these rights, contact [PLACEHOLDER — data controller contact]. For pupil data, requests may need to be routed via the pupil's school where the school is the controller. You also have the right to complain to the UK Information Commissioner's Office (ico.org.uk).
9. Security
We rely on Firebase Authentication and Firestore security rules to restrict access to personal data to the relevant student, their teachers, and site administrators. [PLACEHOLDER — describe any additional organisational/technical measures once confirmed.]
10. Changes to this policy
We may update this policy as the product changes. [PLACEHOLDER — define a real process for notifying schools/users of material changes.]
11. Contact us
Questions about this policy or your data: [PLACEHOLDER — real contact email/address].