Privacy Policy

1. Who we are

Smart Learning Ltd ("Smart", "we", "us", or "our") operates the smartyscholar.com website and associated services. We are registered in England and Wales. If you have any questions about this policy, contact us at privacy@smartyscholar.com.

2. What data we collect

We collect the following categories of personal data:

• Account data: name, email address, and password (stored securely via Clerk)
• Learning data: courses started and completed, XP earned, streak history, quiz responses, and AI tutor conversations
• Payment data: billing information processed securely via Stripe — we never store card details
• Usage data: pages visited, features used, device type, and browser information collected via anonymised analytics

3. How we use your data

We use your data to:

• Provide, personalise, and improve the Smart learning platform
• Process payments and manage your subscription
• Send transactional emails (receipts, account updates)
• Provide parent or teacher visibility where applicable
• Improve course content and AI tutor performance (using anonymised data only)
• Comply with legal obligations

We do not sell your personal data to third parties. We do not use your data for advertising.

4. Legal basis for processing (UK GDPR)

We process your data under the following legal bases:

• Contract: to provide the service you have signed up for
• Legitimate interests: to improve our platform and prevent fraud
• Legal obligation: where required by law
• Consent: for any optional marketing communications

5. Data retention

We retain your account and learning data for as long as your account is active. If you delete your account, we will delete your personal data within 30 days, except where we are required by law to retain it.

6. Third-party services

Smart uses the following third-party services which may process your data:

• Clerk — authentication and account management
• Stripe — payment processing
• Vercel — hosting and infrastructure
• Sentry — error monitoring (anonymised)

Each of these providers has their own privacy policy and is subject to GDPR compliance obligations.

7. Children's privacy

Smart is designed for learners aged 10 and above. We do not knowingly collect personal data from children under 10 without verified parental consent. If you believe a child under 10 has created an account, please contact us at privacy@smartyscholar.com and we will delete the account promptly.

8. Your rights

Under UK GDPR, you have the right to:

• Access the personal data we hold about you
• Correct inaccurate data
• Request deletion of your data
• Object to or restrict processing
• Data portability
• Withdraw consent at any time

To exercise any of these rights, email privacy@smartyscholar.com. We will respond within 30 days.

9. Cookies

We use only essential and functional cookies. We do not use advertising or tracking cookies. See our Cookie Policy for full details.

10. International users and data transfers

Smart is operated from the United Kingdom and primarily governed by UK GDPR. However, we serve users worldwide and apply the same privacy standards globally regardless of location.

• EU/EEA users: Where EU GDPR applies, we process your data on the same legal bases described above and honour all rights afforded under EU GDPR. You may lodge a complaint with your local supervisory authority.
• US users: We do not sell personal data. Californian users may make data requests under CCPA by emailing privacy@smartyscholar.com.
• All other users: We apply UK GDPR standards as a baseline and comply with applicable local data protection laws where required.

Our infrastructure is hosted on Vercel (US-based). Where personal data is transferred outside the UK or EEA, we rely on Standard Contractual Clauses or equivalent safeguards to ensure adequate protection.

11. Changes to this policy

We may update this policy from time to time. We will notify you of significant changes by email or via a notice on the platform at least 14 days before they take effect.

12. Contact and complaints

Smart Learning Ltd
Email: privacy@smartyscholar.com

UK users may lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

EU/EEA users may contact their local data protection authority. A list is available at edpb.europa.eu.