Privacy Policy

Last updated: 28 September 2026

This policy explains what information the BrightMinds app and the BrightMinds website use, why, where it is kept and the choices you have. It is written for parents and carers, with a short version for children first.

1. Who we are

BrightMinds is run by [Owner's full legal name], trading as BrightMinds, [Owner's UK postal address]. We are the "controller" of the personal information described here under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Contact us about privacy at privacy@topmarks.app. ICO registration number: [ICO registration number].

2. The most important thing

We do not run servers that receive your family's information. Everything BrightMinds records is stored on your device and, only if a parent switches it on, in your family's own private iCloud storage, which Apple provides and we cannot access. We do not use analytics, advertising or tracking of any kind.

3. What we use, and why

• Parent account (Sign in with Apple). An account identifier from Apple, and your name and email address only if you choose to share them when signing in (Apple lets you hide your email). Used to create your family account and to know who can give consent and use parent-only features. Legal basis: contract (UK GDPR Article 6(1)(b)).
• Child profiles. The first name or nickname you choose, year group and year of birth (we do not keep the full date of birth). Used to set up the right year's content and to apply the protections for under-13s. Legal basis: the parent's consent for children under 13 (Articles 6(1)(a) and 8), otherwise contract.
• Learning records. Answers given, scores, mistakes, hints used, how a topic felt (an emoji), streaks, points and lesson progress. Used to run the app, show progress to your child and to you, and choose what to practise next. This personalisation happens only inside the app and has no legal or similarly significant effect on anyone. Legal basis: contract, and the parent's consent for under-13s.
• Consent and security records. When consent was given or withdrawn, by which parent account and for which version of this policy, and a log of account actions such as sign-in, data export and deletion. Kept to show we have acted lawfully and to keep accounts secure. Legal basis: legal obligation (Article 6(1)(c)) and our legitimate interest in security (Article 6(1)(f)).
• Settings and parent PIN. Your choices in Settings, and a parent PIN stored only as a secure one-way hash in the device's Keychain.
• Purchases. Subscriptions are sold and handled by Apple. We only learn whether a subscription is active; we never see payment details.
• Voice answers (optional). If your child answers by speaking, the microphone and Apple's speech recognition turn speech into text on the device. Audio is not stored, and is not sent to us or to Apple's servers.
• Face ID or Touch ID (optional). Used to protect parent-only features. iOS checks it and tells the app only yes or no.
• Reminders (optional). Notifications are scheduled on the device and never pass through us.

We do not collect location, contacts, photos, the camera, advertising identifiers, analytics or crash reports, and we do not track anyone across apps or websites. The quiz questions and help text are built into the app and never leave your device.

4. Where it is kept

• On your device, protected by iOS encryption. Deleting the app removes it from the device.
• In your family's iCloud (optional, off until a parent switches it on). Syncs progress between your family's devices using your own private iCloud storage. Apple Inc. provides iCloud under its own privacy policy and may store data outside the UK with its own safeguards. We cannot see or access this data.

5. Who we share it with

We do not sell, rent or share personal information. BrightMinds relies on Apple's built-in services (Sign in with Apple, iCloud, the App Store, Face ID and notifications), which Apple provides under its own terms. We would only disclose information if the law required it.

6. Children

BrightMinds is made for children aged 5 to 11 and follows the ICO's Age Appropriate Design Code (the Children's Code):

• A parent sets up the account and gives consent for children under 13, the UK age of digital consent.
• Settings start at high privacy: iCloud sync is off, nothing is shared, and there is no location or profiling for marketing.
• Children are told, in words they understand, that a grown-up can see their progress.
• There are no adverts. Purchases, sharing and links that leave the app sit behind a parental gate that asks a question for grown-ups.
• We avoid designs that push children to give up privacy or to keep playing when they want to stop.

7. How long we keep it

• Your information stays until you delete it. You can delete an account in the app (Settings, then Privacy & Data).
• A deletion request starts a 30-day window in which it can be cancelled; after that the account and its children's records are permanently removed from the device and iCloud. You can also choose "Delete now" to skip the 30 days.
• Security and consent logs are kept for 12 months, then deleted automatically.
• Deleting the app removes the on-device copy. An iCloud copy remains until you delete it in the app or in your iPhone or iPad's iCloud settings.

8. Your rights

You can ask to see, correct, delete, restrict or move your information, object to how it is used, and withdraw consent at any time. Most of this can be done in the app: Settings, then Privacy & Data (export, delete, withdraw consent). Or email privacy@topmarks.app and we will reply within one month. Parents can use these rights for their children, and children can use them for themselves when they are old enough to understand them.

9. Keeping it safe

Information is protected by your device's encryption, the iOS Keychain and Apple's encrypted iCloud storage. Parent-only areas are protected by a PIN, Face ID or Touch ID, and anything that spends money or leaves the app needs a grown-up to answer a question first.

10. Changes to this policy

If we change this policy we will update this page and tell you in the app. If a change affects what you have agreed to, we will ask again before it applies.

11. Complaints

Please contact us first at privacy@topmarks.app so we can put things right. You can also complain to the Information Commissioner's Office (ICO): ico.org.uk/make-a-complaint or 0303 123 1113.