Privacy Policy
1. Who we are
Pollyana Academy Ltd ("Pollyana Academy", "we", "us") provides two services: The Summer Thinking Space, a live one-to-one maths programme delivered by Pollyana Banerji Patel; and Held to Think, an online maths companion that a child works on with a parent alongside. We are the data controller for the personal information described here.
2. Who this policy is for
Our services are bought and managed by a parent or legal guardian, who must be aged 18 or over and have authority to act for the child. The child works on Held to Think but does not hold an account. We design for children's privacy in line with the ICO Children's Code.
3. The information we collect
- Parent account: name, contact details, age and authority confirmation, and billing information.
- Child profile: a first name or nickname, school year, stage and exam board.
- Intake: the intake uses fixed options, tick boxes and drop-downs, with no free-text field except your child's first name or nickname. It covers things like your goal for your child, preferred rhythm, and any accessibility or pacing preferences, all chosen from set options.
- School: we do not ask for or store your child's school name. We collect only a fixed-option school type, teaching context and the pace of maths teaching, to help shape the programme.
- No uploads: there is no file upload and no school report upload.
- Your child's work: the answers and steps your child types into Held to Think, and a record of what they met and steadied.
We do not ask you for special-category information, such as details about a child's health, SEN or diagnosis. Because the intake uses fixed options with no free-text box beyond your child's first name, there is nowhere to enter that kind of detail. If you contact us separately and choose to share something of that kind, we treat it with the strongest care and only with your explicit consent.
4. Why we use it, and our lawful basis
We use this information to set up the account, shape and deliver the programme, keep your child safe, take payment, and support you. Our intended lawful basis is your explicit consent as the parent or guardian, with an appropriate condition for any special-category data, set purpose by purpose.
5. How long we keep it, and how we delete it
We keep your child's data only for as long as we need it to deliver the service, and then delete it.
For Held to Think, we keep your child's learning data while your subscription is active, and delete it within 30 days of your subscription ending.
For The Summer Thinking Space, we keep your child's material only for as long as we need it to deliver and follow up the sessions, and then delete it. In all cases, deletion removes the data from our active systems, and from our backups and logs as they cycle, so it cannot be restored, and you can ask us to delete it sooner at any time (see Your rights).
6. What we do not do
We do not sell, share or use your family's data for advertising. We do not use your family's data to train or improve our product by default; any such use would require your separate, explicit consent. We do not profile children for marketing. We do not capture your child's voice or video. We do not diagnose, and we do not give medical, therapeutic or emergency advice.
The app captures only the answers and steps your child submits. It does not record keystrokes, pauses, timing, cursor or mouse movement, voice or video, and it does not try to infer your child's mood.
We use Anthropic's Claude only to help generate non-identifying curriculum and practice questions in advance. It is never used for live, child-facing conversation, and we do not send it your child's name or any information that could identify your child.
7. Who can see it
Your child's information is seen only by you, by your child (their own work), and by Pollyana and a small number of approved reviewers for quality and safety. Pollyana may access your child's material to teach it live with your child; this access is recorded. We do not give access to any other third parties, beyond the trusted service providers that help us run the platform securely under contract.
8. Keeping children safe
If anything you share, or anything in your child's work, suggests a risk of harm, we pause normal processing and a member of our team reviews it personally. We will be in touch calmly, and we do not provide emergency advice through the product. Safeguarding decisions are made by our Designated Safeguarding Lead.
Before your child sees any learning content, Pollyana checks and approves it; nothing reaches your child unchecked. If the way we carry out this checking ever needs to change as the number of families grows, we will review and update our Data Protection Impact Assessment and this policy before making that change.
9. Your rights
You can ask to see, correct, export or delete your child's data at any time. When you ask us to delete, we delete fully, including from backups and logs. You can also withdraw consent. To exercise any of these, contact p.banerji@pollyana-academy.com. You have the right to complain to the Information Commissioner's Office.
You can ask us to delete your child's learning data at any time, including while your subscription is active. Because the programme is personalised from that data, deleting it may affect our ability to provide the personalised service, so we may offer you an export of your child's information first.
10. Security and where your data is held
We protect your data with encryption in transit and at rest, least-privilege access, and access logging. We hold data in the United Kingdom; any processing outside the UK would be identified and protected appropriately.
11. Cookies and this website
This website and service are deliberately simple. We use no analytics, advertising cookies, tracking cookies or third-party analytics, and we do not build a profile of you. Any cookies we use are strictly necessary to make the service work, such as keeping you securely logged in and holding your session. If we ever introduce analytics or other non-essential cookies, we will ask for your consent first and update this policy.
12. Payments
Payments are handled by a trusted payment provider. Card details are processed by that provider and are not stored by us. The seller of record is shown at checkout.
13. Our Data Protection Impact Assessment
Because Held to Think is used by children, we have carried out a Data Protection Impact Assessment (DPIA): a careful, structured review of how we use personal information and how we protect it. We follow the Information Commissioner's Office seven-step process. This is a plain-language summary. The full assessment is a working document that we keep under review, and we do not publish the parts that describe our security in detail, so that the detail cannot be misused.
What we looked at. How we collect, use, store and delete the information above; who can see it; how long we keep it; and the fact that a child uses the service. We treat children as needing extra protection, and we treat anything sensitive a parent might type with the strongest care, even though we do not ask for it.
The risks we considered. That a child could be identified from small details; that a parent might try to share sensitive information, which the fixed-option intake, with no free-text box beyond the child's first name, is designed to prevent; that one family's information must never reach another; that any sign a child may be at risk must be handled thoughtfully; that data must be kept secure; and that the learning content a child sees must be safe, accurate and age-appropriate.
How we reduce them. We collect the minimum we need and encourage nicknames rather than full names. There is no file to upload. We host and hold data in the United Kingdom, encrypt it, and limit who can see it. A person reviews and approves the learning content before a child ever sees it. A person, our Designated Safeguarding Lead, reviews any safeguarding concern; the product never tries to handle it automatically and never gives emergency advice. We keep data only for as long as it is needed and then delete it, and you can see, correct, export or delete it at any time.
Our conclusion. After these measures, we assess the remaining risk to a child or family as low. We keep the assessment under review and will repeat it if we change how the service works. No child uses Held to Think, and no payment is taken, until this work is complete and signed off.
If you would like to understand more about how we protect your family's information, please contact us at p.banerji@pollyana-academy.com.
14. Early access and marketing
If you register your interest in Held to Think, we ask for your email address and, if you choose, your child's stage and exam board. We use these only to contact you about Held to Think early access. Our lawful basis is your consent, which you give by ticking the box on the form, and you can withdraw it at any time. Every email we send includes a one-click unsubscribe link, and if you unsubscribe or ask us to delete your details, we do so straight away. We keep your details until you unsubscribe; if you never engage with our emails, we review and delete your details after 18 to 24 months. We never sell or share your details, and we do not use them for anything other than contacting you about Held to Think. Your details are held in our own secure UK database, separate from any information about your child's use of the product.
15. Changes to this policy
We will update this policy as the service develops. The current version and date are shown at the top.
16. Contact
Pollyana Academy Ltd, 124 City Road, London EC1V 2NX. Email: p.banerji@pollyana-academy.com.