🔒 Privacy Policy

1. Who We Are

11+ Vocabulary Practice is operated by BKTY LTD, a private limited company registered in England and Wales.

• Data controller: BKTY LTD
• Registered address: 29 Watts Lane, Rugby, England, CV21 4PE
• Privacy email: [email protected]
• Company number: 12845913
• ICO registration: Pending (application submitted June 2026)

2. Our Approach to Children's Privacy

The Service is intended for children aged approximately 9 to 11 and their parents or guardians. We apply additional protections to children's personal data and design the Service with the best interests of children as a primary consideration.

We do not sell children's personal data, use it for targeted advertising, or use it to build advertising profiles.

3. Personal Data We Collect

Account information

• Parent or guardian email address
• Account username and encrypted authentication credentials
• Parent dashboard PIN

Child profile information

• A chosen display or character name
• A selected avatar or character emoji
• Learning preferences (daily goals, selected reading voice)

Learning and activity information

• Words studied and reviewed
• Quiz answers, answer quality and learning progress
• XP, levels, badges, streaks and completed challenges
• Lesson and review dates

Device and technical information

• Push notification token (if notifications are enabled)
• App version, operating system and device type
• Security and diagnostic logs

We do not request precise location, contacts, photographs, camera access or microphone recordings.

4. Why We Use Personal Data

Purpose	Lawful basis
Account creation and security	Performance of a contract
Delivering personalised lessons	Performance of a contract
Parent dashboard and reports	Performance of a contract
Optional push notifications	Consent
Security and fraud prevention	Legitimate interests
Legal compliance	Legal obligation

5. Sharing Personal Data

We share data only with:

• Hosting provider: Datacamp Limited (UK/EU)
• Expo / EAS: for app delivery and optional push notifications
• Apple App Store: for app distribution

We do not sell or rent personal data. We do not share children's data with advertisers.

6. Data Retention

Data	Retention period
Active account data	While account is active
Deleted account data	Removed within 30 days
Backups	Overwritten within 90 days
Push tokens	Removed when notifications disabled or account deleted
Security logs	90 days

7. Security

We use HTTPS encryption, access controls, and secure credential storage. If a data breach occurs, we will notify affected users and the ICO where required.

8. Your Rights

You have the right to access, correct, restrict, port, or delete your data. Email [email protected]. We respond within one month.

You may complain to the UK Information Commissioner's Office at ico.org.uk/make-a-complaint or call 0303 123 1113.

9. Account Deletion

Email [email protected] with subject "Account deletion request". We complete deletion within 30 days. Deleting the app does not delete your account.

10. Changes to This Policy

We may update this policy when the Service, law or our data practices change. We will provide appropriate notice of significant changes.