Fifteen standards, one at a time.
The ICO’s Age Appropriate Design Code sets fifteen standards for any service children are likely to use. It applies to us whether or not a school is involved, so we have written our position on each one in plain terms rather than summarising them away.
Every answer below was a design decision taken before this page existed. Nothing here was added to satisfy the Code; the page reports what the product already does.
The standards.
| # | Standard | Our position |
|---|---|---|
| 1 | Best interests of the child | A Family restriction keeps its original end time and the completion methods allowed during setup, including offline. An early-unlock request can remain pending until a parent replies. Submitting a privacy request does not immediately remove restrictions. |
| 2 | Impact assessment | In progress; completion is required before Family release. Summary here. |
| 3 | Age-appropriate application | Family child accounts are linked to a household through adult-managed setup. Age assurance and parental-consent checks must be verified before release. |
| 4 | Transparency | There is a privacy notice written for children, not only for adults. In the app, a child is always told who started a restriction, how long it lasts and how to end it. |
| 5 | Detrimental use of data | A child’s data is excluded from reporting at the database level, not by policy. It is never sold, never used for marketing, and never shown to a school or partner. |
| 6 | Policies and standards | Fourteen binding rules for family and child data, published in full. |
| 7 | Default settings | High privacy by default. Every optional collection is off. The time-based end to a restriction is on. |
| 8 | Data minimisation | We keep outcomes, not evidence. A yes or no, not a step count. A completion, not a location. |
| 9 | Data sharing | No child data goes to any third party. No school, venue or partner sees an individual child, at any threshold. |
| 10 | Geolocation | We never store a child’s location, in any form, for anyone. This one is absolute. |
| 11 | Parental controls | A child is always told when a parent’s controls are active and exactly what the parent can see. A child’s own rules and results stay private from their parent. |
| 12 | Profiling | Off, and unavailable. No insights, no recommendations, and children’s data is never used to train anything. |
| 13 | Nudge techniques | A child account has one plain voice. The sharper tones adults can choose are unavailable, and a parent cannot switch them on. No shame for a broken streak, no manufactured urgency, and the app stops repeating itself after the third attempt. |
| 14 | Connected toys and devices | Not applicable. Our tags are passive stickers that hold no personal data. |
| 15 | Online tools | A child can reach their own privacy tools directly. They do not have to ask a parent. |
What we have not done.
We have not consulted children directly. We will consult parents, and our reasoning is that doing research with children would itself mean collecting children’s data for a new purpose — needing its own consent and oversight — which is more intrusive than the thing it would check. Instead the product carries design commitments that stand in its place: a notice written for children, every restriction stating its own duration and way out, and rights tools a child can use without asking.
We will consult children before working with schools, where it is the right thing to do and where a school will rightly ask.
Tell us if we have this wrong.
If you are a parent, a teacher, or a child using this and something on this page does not match your experience, that is worth knowing and we would rather hear it. Contact us, or write to the address in the privacy notice. You can also complain to the Information Commissioner’s Office at any time, and you do not need to come to us first.