SwotHub Privacy Policy

SwotHub is used by three groups of people, and this notice covers all of them.

Account holders. A SwotHub account is always held by an adult, normally a parent, carer or guardian. The account holder enters into the agreement with us, pays for the subscription once subscriptions begin, and sets up a profile for each child.

Children. Children aged 7 to 16 use SwotHub through a profile created by their account holder. Children have their own rights over their own information, and those rights belong to the child rather than to the adult. Section 12 explains how that works in practice.

People on our mailing list. You can give us your email address on our website without opening an account. Section 18 covers that on its own. If you do not have an account, the sections about accounts and children do not apply to you, although section 15 on cookies and section 17 on how to complain do.

Ask CAM is a chat feature inside SwotHub. A child can type a question about their schoolwork and receive an answer. This section explains it in full because it is the part of SwotHub that handles the most sensitive information.

It is not a person. Ask CAM produces answers automatically. It is not a teacher, a counsellor or an emergency service.

There is no messaging between users. SwotHub has no facility for any child to message another child, or for any adult to message a child. Ask CAM is a conversation between a child and software.

Ordinary schoolwork questions. When a child asks an ordinary learning question, the message is sent to our AI supplier, OpenAI, which is based in the United States, so that an answer can be produced. Nothing that identifies the child is sent with it. Not their name, their surname, their age, their school, their account or their results. The question travels on its own. We do not save the conversation. It is cleared when the child closes the chat and we keep no record of what the child typed. Our hosting provider's systems do keep a technical record of what CAM replied, as part of the ordinary running of the service.

Our AI supplier keeps a copy for up to 30 days. OpenAI holds the message and the answer for up to 30 days as an automatic check against misuse of their service, and a reviewer there may read it. After that it is removed from their systems, unless they are legally required to keep it for longer. It is not used to train or improve their models, and they have confirmed that to us in writing. We are seeking to have that 30-day retention removed for our account, and we will update this notice when it is.

If a child reports something CAM said. Every answer CAM gives carries a small flag a child can tap if the answer was wrong, unhelpful or upsetting. If they use it, we keep that answer and the message they sent just before it, so that a person here can see what went wrong and fix it. Both are stored encrypted, and the child is told on screen at the time that we are keeping them. This is the one situation in which part of an ordinary conversation is kept. Reports are about what CAM said, not about the child, and they are held separately from safeguarding concerns.

Messages that suggest a child may be at risk. Before any message leaves SwotHub, it is checked inside our own system. If that check suggests a child may be being hurt, may be at risk of hurting themselves, or may be being drawn towards harm by someone else, the message is not sent to our AI supplier at all. The child receives a prepared reply written by us, which offers support and gives the details of Childline and other services. In that situation a record is kept: the message, the reason it was flagged, the date, and the child's profile and account details. That record is read by a trained person at SwotHub so that they can decide whether anything further needs to be done.

We may also keep a small number of signals rather than messages. Some kinds of harm, such as grooming, do not appear in a single message. They appear as a pattern over weeks. To recognise that, we keep a short list of the types of concern raised, with dates and a count, on the child's profile. That list contains no message text. It is kept for 30 days on a rolling basis.

We also keep a daily message count for each child so that the feature is not overused. That is a number and a date, nothing more.

We do not show these records to the account holder. This is a deliberate decision and section 7 explains it.

A concerning message is never emailed to anyone. The person who reviews it is alerted that something needs attention, and has to sign in to SwotHub to read it. That way a child's words stay inside the service rather than sitting in a mailbox.

What Ask CAM will not do. It will not give the answers to quiz questions, because a quiz is meant to show what the child can do on their own. It will not give an opinion on contested political questions, and it will not debate with a child who repeats extremist views back to it.

Limits. Ask CAM is not always right. Children are told, inside the chat, that it can make mistakes and that a teacher or a trusted adult is the person to ask about anything important.

Subscriptions. SwotHub is free to use at present. There is no subscription to buy, and no payment details are collected from anyone. When subscriptions begin they will be bought through the Apple App Store or Google Play. Apple or Google will act as the seller, take the payment and hold the payment details, and we will receive confirmation that a subscription is active along with a subscription reference. We will never see or hold your card number, and we will update this notice before any subscription is sold.

Adding money to fund rewards. When rewards are operating, an account holder can add money to their SwotHub account so that their child's rewards can be paid. Those payments are taken by Stripe, our payment provider. Stripe collects and holds the card details directly, and we receive only confirmation that the payment succeeded, the amount, and a reference. We never see or hold full card numbers. This is not operating at present and no card details are collected.

Rewards are not operating. Children are not currently earning money for passing a quiz. No reward is worked out, credited or paid, and no balance is shown anywhere in the app. Quiz results, scores and progress are still recorded, and section 3 explains what those are used for.

Prepaid cards. The prepaid card feature is not yet operating. No card is issued, no card is ordered, and no card or banking information is collected. When the feature launches we will appoint a regulated card issuer, name them here, and update this notice before any card information is collected. The issuer will be responsible in their own right for the card account and will have their own privacy notice.

Records from before these features were switched off. Where a payment was taken or a reward was credited in the past, we keep the record of it. Those are financial records and we keep them for six years to meet our tax and accounting duties, as set out in section 11.

Automated decisions. Whether a quiz has been passed is decided automatically by the software, with no person involved. You or your child can ask for a person at SwotHub to look at a result again, explain it, and put it right if it was wrong. Write to info@swothub.co.uk.

Most of what SwotHub holds about a child is visible to their account holder. Quiz results, progress, badges and written work are all shown on the parent dashboard, and that is deliberate.

Records created by the Ask CAM safety system are the exception. They are not shown to the account holder, and there is no setting that turns them on.

We have made that choice knowingly, and this is our reasoning. A child who is being hurt is most often being hurt by someone they live with. A child who knows that everything they type will be shown to the adults at home will not type it. If we passed a disclosure straight back into the household, we could put the child in more danger than they were in before. The purpose of the feature is to protect the child, and to do that it has to be safe for the child to use.

We recognise that this is unusual to read as a parent. We would rather set it out plainly here than have you discover it later.

Where a child submits a piece of writing in a writing practice module, the writing is kept on the account and can be seen by the account holder. Written work is not marked, scored or paid on. It is checked automatically for signs that the child may be at risk, and a concern found in written work is handled in the same way as one found in Ask CAM.

Written work sent for that check is not kept by our AI supplier at all. The safety check they provide holds nothing, so the 30-day retention described in section 5 does not apply to written work. It is not used to train or improve any AI model.

Some of the suppliers above are based outside the United Kingdom, mainly in the United States. Where information is sent outside the United Kingdom we rely on one of the safeguards the law allows: an adequacy decision made by the UK government, the UK Addendum to the European Commission's standard contractual clauses, or the UK extension to the Data Privacy Framework, depending on the supplier. We have written data processing agreements in place with the suppliers who handle information about children, including our hosting provider and our AI supplier.

Our app and its database are hosted in the United States. Storing data in the United Kingdom or the European Union is not available on our current plan with our hosting provider, and we will move to it when it is. Our hosting provider processes personal information under a data processing agreement, and relies on standard contractual clauses or the Data Privacy Framework for transfers.

You have the right to ask for a copy of the information we hold about you, to have it corrected, to have it deleted in some circumstances, to restrict or object to how we use it, and to receive it in a portable form. You can also withdraw consent where we relied on consent.

Whose right it is. The rights over a child's information belong to the child, not to the parent. A parent can exercise those rights on the child's behalf, but only where the child is not old enough or able enough to do so themselves, and only where doing so is in the child's best interests. In the United Kingdom a child of around 12 or older is generally treated as able to exercise their own rights, depending on the child.

What that means for a request about a child. When an account holder asks for a copy of a child's information, we will consider whether the child can make that decision themselves, and whether releasing the information is in the child's interests. Where a child is old enough, we will ask the child.

Safeguarding records. Some information may be withheld. That includes information which is also about another person, which a record of a disclosure almost always is, and information whose release could interfere with the prevention or detection of crime. We will always tell you that a request has been dealt with and explain your right to complain, even where we cannot release everything.

Children can ask us directly. A child can write to info@swothub.co.uk and ask what we hold about them without going through their parent.

We will respond within one month. If a request is complex we may extend that by up to two further months, and we will tell you if we do.

In the app. Open Settings, choose Account, then Delete account. You can delete a single child's profile the same way, from that child's entry under Settings.

Without using the app. Email info@swothub.co.uk from the address the account is registered to and ask us to delete your SwotHub account. You do not need to reinstall the app to do this. We will confirm and complete it within one month, and usually much sooner.

What is deleted. The account holder's own record, including name and email address. Every child profile on the account. Quiz results, scores and progress. Written work submitted in the writing practice modules. Lesson progress, saved settings, and any reports or feedback sent from the account. Deletion is immediate and permanent. We do not freeze or suspend the account instead.

What is kept, and why. Two things are kept, and both are explained in section 11.

Financial and payment records are kept for six years to meet tax and accounting duties. They are stripped of the name and email address they belonged to, so they no longer identify anyone.

Records created by the Ask CAM safety system, where a child said something suggesting they may be at risk, are kept until that child's 25th birthday, or longer where the police or the Crown Prosecution Service are involved. These are not deleted when an account is closed. A child who tells us something at eight years old cannot bring a claim of their own until they are eighteen, and deleting the record would destroy it before the person it concerns is old enough to use it. This applies whoever asks for the deletion.

If you would like a copy of what we hold before you delete it, ask us first at info@swothub.co.uk, because once an account is deleted we cannot recover it.

Connections are encrypted. Everything sent between your device and SwotHub travels over an encrypted connection, using TLS 1.2 or above, so it cannot be read in transit.

The database is encrypted where it is stored. Our hosting provider encrypts stored data using AES-256. That covers the database, uploaded files, backups and the keys we keep in their secure store. They are independently certified to SOC 2 Type II and ISO 27001.

The most sensitive information is encrypted a second time, on its own. Two things are treated differently from everything else: what a child writes in the writing practice modules, and any message kept by the Ask CAM safety system, together with the notes a reviewer adds to it. Those are scrambled before they are saved, using a key held separately from the database and not stored alongside it. If a copy of our database were ever taken, those words would not be readable in it.

They are turned back into readable text only when the right person asks for them: a child and their account holder for the child's own written work, and the safeguarding reviewer for a flagged message. Every one of those requests is checked by our own systems rather than trusted from the browser.

Who can reach a safeguarding record. Access is limited to named people, that limit is enforced by the database itself rather than by the page, and every time such a record is opened we log who opened it and when.

And the ordinary measures. Passwords are stored in a scrambled form that nobody at SwotHub can reverse. Full payment card numbers never reach our systems at all.

We follow the Information Commissioner's Age Appropriate Design Code, which sets the standards expected of services likely to be used by children in the United Kingdom.

In practice that means: we collect the least information we need; we do not profile children for advertising and we carry no advertising; there are no public profiles, no followers and no messaging between users; children are told inside the app what CAM does with what they type; and settings that affect a child are set to the most protective option by default.

The swothub.co.uk website is built using GoDaddy's website builder, which sets cookies of its own. Some are necessary to make the site work and cannot be turned off. Others are used to understand how the site is being used.

When you first visit the website you are asked which cookies you accept. You can change that choice at any time using the same control, and refusing the optional ones does not stop you using the site.

The SwotHub app sets no advertising cookies, carries no advertising, and does not track you or your child across other apps or websites. Section 19 explains the software included by the tool we use to package the app.

We will publish any change here. Where a change is significant, we will tell account holders by email rather than relying on them noticing.

Existing account holders will be told about this version directly. It is not enough to show it only to people who sign up after today.

Write to us first at info@swothub.co.uk and we will try to put it right.

If you are not satisfied, you can complain to the Information Commissioner's Office, which is the UK regulator for data protection. Their helpline is 0303 123 1113 and their website is ico.org.uk. You can complain to them at any time, and complaining to us first does not affect that right.

You can give us your email address on our website to hear about SwotHub. You do not need an account to do this, and joining the list does not create one.

What we collect. Your email address, and your first name if you give it.

Why. To send you occasional emails about SwotHub, what we are building, when it opens, and how to take part.

Our lawful basis. Your consent. You give it by ticking the box on the form, and you can withdraw it at any time. Withdrawing it is as easy as giving it: use the unsubscribe link at the bottom of any email we send, or write to info@swothub.co.uk. We will stop, and we will keep a note of your address only so that we do not email you again by mistake.

Who it is for. The mailing list is for parents and carers. Please do not sign up if you are under 18.

How long we keep it. Until you unsubscribe, or until we have not heard from you for two years, whichever comes first.

Who else sees it. GoDaddy, who host our website, send these emails for us. We do not sell your address, we do not share it for anyone else's marketing, and we do not use it for advertising.

Your rights. The rights set out in section 12 apply to this information too. You can ask us what we hold, ask us to correct it, or ask us to delete it.

Our app is built and packaged using a third-party tool. The shell that tool wraps around SwotHub brings some things with it that we did not add and cannot remove. We would rather explain them than leave you to find them in the store listing.

An identifier is created on Android. The Android version contains a notification service belonging to Wix, the company that owns the platform our app is built on. We have never switched push notifications on and we have no notification service of our own, but because that configuration is present it starts up and creates an installation identifier for the device. Wix is already named as one of our platform provider's own suppliers, so this sits within the contract we have with them.

What we do not yet know is what that identifier is used for, how long it is kept, or whether it can be switched off for an app that does not use notifications. We have asked those questions in writing and we will update this notice when we have the answers. The iPhone version contains the same software but no configuration for it, so on the evidence we have it stays dormant and creates nothing.

The permissions the store listing shows. If you look at SwotHub in the App Store or on Google Play you will see a list of capabilities: contacts, calendar, location, microphone, photos, Bluetooth and others. Those come from the packaging tool rather than from SwotHub, and our platform provider has confirmed they cannot be edited or removed. Listing a capability is not the same as using it.

The only one SwotHub actually uses is the camera, for scanning a QR code, and your device will ask you before it is used. We do not collect or ask for your contacts, your calendar, your location, your microphone, your photos or your Bluetooth.

No advertising identifier. Neither version of the app can collect an advertising identifier. The Android version does not request the permission needed to read one, and the iPhone version shows no tracking prompt. There are no advertising networks in either.