Privacy Policy

Effective Date: July 21, 2025

Last Updated: July 21, 2025

1. Introduction

The Privacy Policy explains how Edly collects, uses, and protects your personal information when you use our AI-powered educational mobile application, ("App") which is available on iOS and Android platforms in the United Kingdom.

We are committed to protecting your privacy and complying with UK data protection laws, including the UK Data Protection Act 2018, UK GDPR regulations with respect to children’s data and the Age-Appropriate Design Code (Children's Code).

2. Who We Are

Data Controller: Edly
Contact: mahesh@edly.uk
Data Protection Officer: mahesh@edly.uk

3. Information We Collect

3.1 Personal Information you provide

  • Account Information: Name, email address, age verification details
  • Educational Profile: Academic level, subjects of interest, learning preferences
  • Parental Consent: For users under 18, we collect parental consent records
  • Support Communications: Messages sent to our customer support team

3.2 Information collected

  • Usage Data: App features used, time spent, learning progress, assessment scores
  • Device Information: Device type, operating system, app version, device identifiers
  • Technical Data: IP address (anonymised for users under 18), crash reports, performance metrics
  • AI Interaction Data: Questions generated, topics selected, learning patterns

3.3 Information which is not collected

  • Location Data: We do not collect precise location information from users under the age of 18
  • Behavioural Advertising Data: No tracking for marketing purposes for minors
  • Personal Photos/Videos: Children cannot upload or share multimedia content
  • Social Information: No social networking features are available for users under the age of18

4. How we use your Information

4.1 Educational Purposes

  • Generate personalised AI-powered question papers and assessments
  • Track learning progress and provide educational recommendations
  • Adapt content difficulty to individual learning levels
  • Provide usage statistics to parents/guardians

4.2 App Functionality

  • Create and maintain user accounts
  • Process in-app purchases and subscriptions
  • Provide customer support and respond to enquiries
  • Provide important updates about the App

4.3 Safety and Compliance

  • We verify age and obtain parental consent where required
  • Content monitoring for child safety and appropriateness is in place
  • We ensure compliance with legal frameworks and regulatory bodies
  • Robust authentication and vigilant monitoring is in place to prevent fraud, abuse, and unauthorised access

4.4 AI Content Improvement

  • We analyse usage patterns to improve AI-generated content quality
  • We identify and correct errors in the educational materials
  • Enhancing curriculum alignment and educational effectiveness by defining clear learning outcomes

IMPORTANT DISCLAIMERS AND LIMITATIONS:

  • PRODUCT LIABILITY DISCLAIMER: THE APP AND ALL AI-GENERATED CONTENT ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND. WE EXPRESSLY DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON-INFRINGEMENT, AND ACCURACY OF AI-GENERATED EDUCATIONAL CONTENT.
  • NO EDUCATIONAL GUARANTEES: We make no representations or warranties that use of our App will improve educational outcomes, exam performance, or academic achievement. All educational results depend on individual effort and circumstances beyond our control.
  • AI CONTENT LIMITATIONS: Our AI technology is experimental and may produce incorrect, incomplete, or inappropriate content. Users acknowledge that AI-generated materials require human verification and should not be relied upon without independent validation by qualified educators.

5. Legal Basis for Processing (UK GDPR)

5.1 For Adult Users (18+)

  • Contract Performance: To provide educational services as outlined in our Terms and Conditions
  • Legitimate Interest: To improve our services and ensure platform security

5.2 For Children (Under 18)

  • Parental Consent: Primary legal basis for processing children's personal data
  • Vital Interests: For child safety and protection purposes
  • Legal Obligation: To comply with UK child protection requirements

6. Child-specific Privacy Protections

6.1 Age-Appropriate Design

  • Data minimisation: We only collect data, which is necessary for educational functionality
  • Default high privacy settings for all users under 18
  • The app does not support any behavioural advertising or profiling of children
  • Built-in usage time controls and break reminders

6.2 Parental Rights and Controls

  • Access: Parents can request copies of their child's data
  • Correction: Parents can correct inaccurate information
  • Deletion: Parents can request deletion of their child's account and data
  • Objection: Parents can object to certain data processing activities
  • Withdrawal: Parents can withdraw consent at any time by contacting us

6.3 Enhanced Safety Measures

  • All AI-generated content is filtered for age-appropriateness
  • No direct communication features between users under the age of18
  • Immediate reporting mechanisms for safety concerns are in place
  • Regular safety audits and risk assessments are undertaken

7. Data Sharing and Disclosure

7.1 Personal Data

We will not sell, rent, or trade personal information to third parties for marketing purposes.

7.2 Limited Sharing Scenarios

We may be required to share your details with the following entities:

  • App Store Partners: Apple App Store and Google Play Store for payment processing
  • Technical Service Providers: Cloud hosting, analytics, and security services (with strict data processing agreements)
  • Legal Requirements: When required by UK law or a court order
  • Child Safety: With appropriate authorities, should there by a child protection concern arising

7.3 International Transfers

  • Data is primarily processed within the UK
  • Any international transfers comply with UK GDPR adequacy decisions
  • Appropriate safeguards are in place for all data transfers

8. Data Retention

8.1 Account Data

  • Active Accounts: User account data is retained while account remains active
  • Inactive Accounts: User account data is deleted after 2 years of inactivity (1 year for child accounts)
  • Deleted Accounts: User account data is permanently deleted within 30 days of account deletion

8.2 Child-Specific Retention

  • Children' s account data is retained for the minimum period required.
  • Automatic deletion of a child account is enabled, when the child reaches 18 years of age (unless they choose to maintain adult account)
  • Parents can request immediate deletion of a child’s account at any time by contacting us

8.3 Legal Compliance

  • Some data may be retained longer to comply with legal obligations
  • Safety-related records may be kept for child protection purposes

9. Data Security

9.1 Technical Safeguards

  • End-to-end encryption is in place for sensitive data
  • Secure cloud infrastructure with regular security updates
  • Multi-factor authentication is in place for administrative access
  • Regular security audits and penetration testing are undertaken

9.2 Organisational Measures

  • Staff are trained on data protection and child safety procedures
  • Access controls limiting who can view personal data are in place
  • Data breach response procedures are in place
  • Regular compliance reviews are undertaken

9.3 Child-Specific Security

  • Enhanced security measures are in place for children's accounts
  • Additional monitoring is undertaken for unusual activity
  • Immediate alert notifications are enabled for potential safety concerns

10. Your Rights under UK GDPR

10.1 Individual Rights

  • Right to be Informed: Individuals have the right to be informed about how their personal data is being processed, including the purpose, legal basis and categories of data
  • Right of Access: Individuals can request to access their personal data and supplementary information, such as the purpose of processing, the categories of data and the receipients of the data.
  • Right to Rectification: If personal data is inaccurate or incomplete, then individuals have the right to request that it be corrected or updated.
  • Right to Erasure (Right to be forgotten): Individuals can request the erasure of their personal data in certain circumstances, such as when the data is no longer needed for the purposes for which it was collected, when processing is based on consent and consent has been withdrawn, or when the individual objects to processing.
  • Right to Restrict Processing: Individuals can request that the processing of their personal data be restricted in certain situations, such as when they have contested the accuracy of the data or when the processing is unlawful.
  • Right to Data Portability: This right allows individuals to receive their personal data in a commonly used, machine-readable format and to transmit it to another controller. Right to Object: Individuals have the right to object to the processing of their personal data in certain circumstances, such as when the processing is for direct marketing or for research purposeRights Related to Automated Decision Making and Profiling:
  • Individuals have the right not to be subject to a decision based solely on automated processing, including profiling, if it produces legal effects or significantly affects them.

10.2 Exercising your Rights

You can contact our Data Protection Officer at mahesh@edly.uk to exercise any of these rights. We will respond at the latest within one month of receiving your request.

10.3 Right to Complain

You have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at www.ico.org.uk or by calling 0303 123 1113.

11. Cookies and Tracking Technologies

11.1 Essential Cookies

We use necessary cookies to ensure the App functions properly and securely.

11.2 Analytics

  • Limited analytics to improve app performance
  • No behavioural tracking for users under the age of 18
  • All analytics data is anonymised

11.3 No Advertising Cookies

We do not use advertising cookies or tracking technologies for marketing purposes, especially for users under the age of 18.

12. Third-Party Services

12.1 App Store Integration

  • Apple App Store and Google Play Store fare the primary platforms for distributing mobile apps and handling in app purchases.
  • App stores are subject to their respective privacy policies
  • We do not control their data practices

12.2 Educational Content Links

  • App may contain links to educational resources
  • Third-party sites will have their own privacy policies
  • We are not responsible for third-party privacy practices

13. Changes to this Privacy Policy

13.1 Notification of Changes

  • We will notify users of material changes through the App
  • We will email notifications to registered users (and parents for child accounts)
  • We’ll aim to provide at least 30 days’ notice for significant changes affecting children

13.2 Continued Use

Continued use of the App after changes constitutes to acceptance of the updated Privacy Policy.

14. Contact Information

14.1 General Privacy Enquiry

Email: info@edly.uk

14.2 Child Safety and Data Protection

Data Protection Officer: mahesh@edly.uk
Child Safety Officer: mahesh@edly.uk
Parent/Guardian Enquiry: info@edly.uk

14.3 UK Regulatory Bodies

Information Commissioner's Office (ICO): ico.org.uk
Ofcom: ofcom.org.uk
UK Safer Internet Centre: saferinternet.org.uk

14.4 Emergency Child Safety Concerns

Report immediately to local authorities
NSPCC Helpline: 0808 800 5000
Childline: 0800 1111

15. COMPREHENSIVE LIABILITY LIMITATIONS AND LEGAL DISCLAIMERS

15.1 Maximum Limitation of Liability

  • TO THE FULLEST EXTENT PERMITTED BY UK LAW: TOTAL LIABILITY CAP: Our total liability to you for all claims arising from or relating to this Privacy Policy, the App, AI-generated content, or any data processing activities SHALL NOT EXCEED the amount you have paid us in the 12 months preceding the claim, or £10 (whichever is greater).
  • EXCLUDED DAMAGES: WE WILL NOT BE LIABLE FOR ANY: Indirect, incidental, special, consequential, or punitive damages; Loss of profits, revenue, data, or business opportunities; Educational or academic losses or setbacks; Costs of substitute products or services; Emotional distress or reputational harm; Losses due to AI content errors or inaccuracies; Damages arising from third-party actions or app store issues

15.2 Force Majeure and Technical Limitations

  • We are not liable for any failures, delays, or issues caused by: Internet connectivity problems or device malfunctions; App store policies, updates, or removals; Acts of god, natural disasters, or government actions; Cyber-attacks, data breaches beyond our reasonable control; AI technology limitations or unexpected AI behaviours; Educational curriculum changes or exam requirement modifications

15.3 User Assumption of Risk

  • By using Edly, you acknowledge and agree that: You use the App and AI-generated content at your own risk; You are solely responsible for verifying all educational content; You will not rely solely on AI-generated materials for academic decisions; You understand AI technology has inherent limitations and potential errors; You accept responsibility for any consequences of App usage

15.4 Indemnification Clause

  • You agree to indemnify, defend, and hold harmless [Company Name], its officers, directors, employees, agents, and affiliates from and against any and all claims, damages, losses, costs, investigations, liabilities, judgments, fines, penalties, settlements, interest, and expenses (including attorneys' fees) that directly or indirectly arise from or are related to: Your use or misuse of the App or AI-generated content; Your violation of this Privacy Policy or Terms and Conditions; Your violation of any rights of another person or entity; Any false, inaccurate, or misleading information you provide; Any educational decisions made based on the App content

15.5 Dispute Resolution and Jurisdiction Limitations

  • MANDATORY ARBITRATION CLAUSE (Where Legally Permitted): Any disputes not involving child safety or data protection rights shall be resolved through binding arbitration; Arbitration shall be conducted under UK Arbitration Act 1996; You waive the right to participate in class action lawsuits where legally permissible; All arbitration proceedings shall be confidential
  • JURISDICTION RESTRICTIONS: Any legal proceedings must be brought in the courts of England and Wales only; You waive any right to bring proceedings in any other jurisdiction; Claims must be brought within 12 months of the issue arising (where legally permissible)
  • GOVERNING LAW SUPREMACY: This Privacy Policy will be governed exclusively by the laws of England and Wales, without regard to conflict of law principles.

15.6 Severability and Enforcement

  • If any provision of these limitations is deemed unenforceable by a court, the remaining provisions shall remain in full force and effect. Where limitations are reduced by law, they will be enforced to the maximum extent legally permissible.

15.7 No Class Actions

  • To the fullest extent permitted by law, you agree that any dispute resolution proceedings will be conducted only on an individual basis and not in a class, consolidated, or representative action.

15.8 Statute of Limitations

  • Any claim against us must be brought within one year of the date the claim arose, or such claim will be permanently barred, regardless of any statute of limitations that might otherwise apply.

15.9 Waiver of Certain Rights

  • By using Edly, where legally permissible, you waive: Any right to a jury trial; Any right to punitive or exemplary damages; Any right to injunctive relief (except for intellectual property violations); Any right to attorney's fees and costs

15.10 Survival Clause

  • These limitation provisions will survive termination of your account, discontinuation of the App, or any other end to our relationship.

16. ADDITIONAL COMPREHENSIVE DISCLAIMERS

16.1 Educational Content Disclaimers

  • NO EDUCATIONAL WARRANTIES: We provide no guarantees about educational effectiveness, exam preparation adequacy, or academic improvement
  • CURRICULUM ALIGNMENT: While we aim for UK National Curriculum alignment, we make no warranties about complete accuracy or current compliance
  • TEACHER REPLACEMENT: Our App is not intended to replace qualified teachers or formal education
  • LEARNING OUTCOMES: Individual learning results may vary significantly and depend on factors beyond our control

16.2 AI Technology Disclaimers

  • EXPERIMENTAL TECHNOLOGY: Our AI is continuously evolving and may produce unexpected or incorrect results
  • NO HUMAN OVERSIGHT GUARANTEE: Not all AI-generated content receives human review before delivery
  • BIAS AND ERRORS: AI systems may contain inherent biases or produce discriminatory content despite our efforts to prevent this
  • TECHNICAL FAILURES: AI systems may experience downtime, errors, or complete failures without notice

16.3 Data Security Limitations

  • While we implement reasonable security measures, we cannot guarantee: Complete protection against all cyber threats; Prevention of all unauthorised access attempts; Immunity from sophisticated hacking techniques; 100% uptime or availability of security systems

16.4 Third-Party Integration Risks

  • We are not responsible for: App store policy changes affecting app availability; Third-party service failures or security breaches; Changes to device operating systems affecting app functionality; Internet service provider issues or restrictions

17. Accessibility

This Privacy Policy is available in accessible formats. If you need assistance accessing this information, please contact us at info@edly.uk.

16. Additional UK-Specific Provisions

16.1 Consumer Rights Limitations

While UK Consumer Rights Act 2015 provides certain mandatory protections that cannot be waived, our liability for any statutory consumer rights violations is limited to the maximum extent permitted by law.

16.2 Educational Standards Disclaimer

Our data practices support general compliance with UK National Curriculum standards, but we make no warranties about complete accuracy, current compliance, or educational effectiveness for any specific exam board or qualification.

16.3 Brexit Compliance

Our privacy practices complies with UK data protection requirements independent of EU GDPR obligations. However, changes in UK law may affect service availability or functionality without notice.

16.4 GDPR Rights Limitations

  • While we respect your UK GDPR rights, we reserve the right to: Charge reasonable administrative fees for excessive or repetitive requests; Refuse manifestly unfounded or excessive requests; Require additional verification for data subject requests; Take up to 3 months for complex requests (with notification)

17. INTERNATIONAL USER RESTRICTIONS

17.1 Service Availability

  • This App is designed for UK users and may not be available in all countries
  • Use from outside the UK may result in reduced functionality or service termination
  • We make no representations about legality of use in other jurisdictions

17.2 Cross-Border Legal Immunity

  • We cannot be held liable for violations of non-UK laws or regulations
  • Users accessing from outside the UK will do so at their own risk
  • International users waive any claims under their local consumer protection laws where legally permissible

FINAL COMPREHENSIVE DISCLAIMER:

BY USING EDLY, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY ALL LIMITATIONS, DISCLAIMERS, AND WAIVERS CONTAINED IN THIS PRIVACY POLICY. YOU UNDERSTAND THAT YOUR USE OF THE APP IS AT YOUR SOLE RISK AND THAT WE PROVIDE NO GUARANTEES OR WARRANTIES BEYOND THOSE REQUIRED BY MANDATORY UK LAW.

YOU SPECIFICALLY ACKNOWLEDGE THAT: AI-generated content may contain errors and should always be verified; Educational outcomes depend on individual effort and are not guaranteed; Technical failures and security incidents may occur despite our precautions; Our total liability to you is strictly limited as set forth above; You assume all risks associated with using experimental AI technology for educational purposes.

WARNING: This is an AI-powered educational tool with inherent limitations. It should supplement, not replace, traditional education methods and qualified instruction.

Last Updated: July 21, 2025

Version: 2.0 (Enhanced Legal Protection)

This Privacy Policy should be read in conjunction with our Terms and Conditions. Both documents together form the complete agreement regarding data privacy, product liability, and legal limitations. You acknowledge and agree to these terms, by continuing to use the App.