Legal Document
At Revision Genie, we are committed to following the ICO's Age Appropriate Design Code, which sets out standards for online services likely to be accessed by children. Here's how we implement these standards:
1.1 Our platform is designed with children's educational needs as the primary focus.
1.2 We regularly assess and document how our service supports children's educational development.
1.3 All features are designed to enhance learning while maintaining safety and wellbeing.
2.1 We conduct regular DPIAs specifically considering risks to children.
2.2 Our assessments cover all aspects of data processing that might affect children.
2.3 We maintain detailed documentation of our risk mitigation strategies.
3.1 Our content and features are tailored to different age groups and educational levels.
3.2 We implement age-appropriate user interfaces and content delivery.
3.3 Security measures are enhanced for younger user accounts.
4.1 We provide clear, age-appropriate privacy information.
4.2 Our terms, policies, and community standards use simple language.
4.3 We use child-friendly ways to tell users how we use their personal data.
5.1 We never use children's personal data in ways that could be detrimental to their wellbeing.
5.2 Our AI tutoring system is designed to support, not manipulate or exploit.
5.3 We regularly review our data practices to prevent harmful impacts.
6.1 We uphold and enforce clear standards of behavior.
6.2 Our policies are written in age-appropriate language.
6.3 We actively monitor and enforce our community guidelines.
7.1 We apply privacy-protective defaults to every account, whatever the user's age: minimal data collection, no advertising or behavioural profiling, and no precise location.
7.2 Students who tell us at registration that they are under 16 get two further defaults, applied automatically at the moment the account is created. First, their name is hidden from other people's leaderboards: on school and class boards other students see an anonymous entry instead of their name, and on friends boards they do not appear at all. Second, we do not record approximate location on their account.
7.3 Neither of those defaults stops the student using anything. They can still see and take part in leaderboards, and they can turn their visibility back on themselves at any time in Settings. We think a default a child cannot undo is a worse outcome than one they can, so the leaderboard default is reversible and neither default is hidden from them.
7.4 We do not offer a per-user profile visibility switch, and we do not claim one. What exists is the leaderboard control described above, which every student has, and a school-level setting that lets a school restrict its students' profiles so they are visible only within that school. Where a school turns that on, it applies to all of that school's students and is controlled by the school.
7.5 Precise location tracking is not simply switched off, it does not exist in the service: we never ask your browser or device for your location and we never use GPS. See section 10 for what we do hold.
7.6 We do not provide open one-to-one free-text private messaging between users. There is no direct-message inbox or open chat between strangers. Class messaging is school-managed, moderated and class-scoped.
7.7 Some features do allow limited interaction between users - for example following another user, friends leaderboards, public profiles, sharing a custom genie via a link, and joining a multiplayer live quiz by code. These are structured, low-risk interactions rather than open messaging: there is no free-text private chat, display names in live quizzes are filtered by a moderation list, precise location is never shared, and users can block other users and report content or behaviour. Live quizzes do not include livestreaming, voice or video.
7.8 We monitor developments in UK online safety law, including measures relating to interaction between adults and children on online services, and will adjust these features and their defaults if and where we are required to do so.
8.1 We collect only the minimum amount of personal data needed to provide our educational service.
8.2 Data collection is proportionate to the user's age and our educational purpose.
8.3 Regular data audits ensure we maintain minimal data collection.
9.1 We never share children's personal data with third parties for commercial purposes.
9.2 Data sharing is limited to what's necessary for educational services.
9.3 We maintain strict controls over any data sharing arrangements.
10.1 We do not collect precise geolocation data. There is no GPS, and we never ask your browser or device where you are.
10.2 The only location information we hold is approximate: the country, region and town that our hosting provider works out from the internet connection itself. We use it in aggregate, for example a count of visitors per town, and to help keep the service secure. We do not store the IP address it was derived from.
10.3 We do not record that approximate location on the account of a student who registered as under 16. Their visits still count towards anonymous daily totals per town, which contain no reference to any user or device.
10.4 There are no location-based features in Revision Genie. Nothing in the product shows one user where another user is, and no content is targeted by location.
11.1 Parents and guardians can create a parent account and link it to their child's account, which gives them a view of how their child is getting on.
11.2 Linking always starts with the child. The child displays a short-lived code in their own settings, and the parent enters that code on their own account. There is no way for an adult to claim a child's account from the outside.
11.3 A linked guardian sees learning signals only: progress, homework status, streaks, activity level, subjects and grade estimates, mock exam results where a teacher has released them or the child marked them, remaining AI allowance, and any revision tasks the guardian has set. They can also receive an optional weekly summary by email, and can buy the child a paid plan as a gift.
11.4 A linked guardian can never read the child's conversations with our AI tutors, their notes or uploaded files, their social connections, or any safeguarding information. That limit is deliberate: a child who believes a parent is reading their chats will not use the service to ask for help.
11.5 The child stays in control of the link. They are told when a guardian links to them, they can always see who is linked in their settings, and they can remove a guardian at any time without needing anyone's permission. The link record is deleted when either side removes it, or when either account is deleted.
11.6 A parent account does not allow a child under 13 to use the service. Children must be at least 13 to register their own account, and younger students can use Revision Genie only through an account created and managed by their school or teacher. We recommend that parents and guardians of younger teenagers stay involved in their child's online learning and read these policies together. See our Terms and Conditions for our age rules.
11.7 Where a child uses Revision Genie through their school, oversight is also provided by the school: teachers and school admins can see that student's activity and progress where the school has authorised it.
11.8 Alongside all of this, the privacy-protective defaults in section 7 apply automatically, so a child is protected by default without a parent needing to configure anything.
11.9 If a parent or guardian has a concern about their child's use of Revision Genie, they can contact us at support@revisiongenie.com and we will help.
12.1 We use profiling only for educational purposes (e.g., personalising learning paths).
12.2 Profiling settings are set to high privacy by default.
12.3 We regularly review profiling practices to ensure they benefit the child's education.
13.1 We avoid nudge techniques that might encourage children to provide unnecessary personal data.
13.2 Any engagement features focus solely on educational benefits.
13.3 We regularly review our interface design to avoid harmful nudge techniques.
13.4 Push notifications are opt-in and are not used to pull a child back to the service. We ask once and once only, never when a page loads, and never before a student has earned a daily streak, so we only ask people who have already used Revision Genie properly. The two answers are offered as buttons of the same size, side by side, and the card says what would be sent and when before it asks. A no is remembered on the account rather than in the browser, so it survives a new device or a cleared browser and we do not ask again. Nothing is delivered between 9pm and 7am UK time, for every user of every age. There is one kind of notification, an invitation to a live quiz, and its wording is the same wording as the message in the app: we do not send countdowns, warnings that a streak is about to end, or anything suggesting a student has let someone down.
14.1 Our platform is web-based and does not connect to external toys or devices.
14.2 Any future integrations will undergo strict safety assessments.
14.3 We maintain clear documentation about device connections.
15.1 We provide prominent and accessible tools for children to exercise their data protection rights.
15.2 Our help and support features are easy to find and use.
15.3 We offer clear ways to report concerns or seek support.
For questions about how we implement the Children's Code or to report concerns, please contact our Data Protection Officer, Joel Martin, at joel@revisiongenie.com.