Last updated: 30 July 2026
This Privacy Policy explains how 11+ Tutor, operated by PassEleven Ltd (company number 17408473, registered office 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ) ("we", "us"), collects and uses personal data when a parent or guardian ("you") uses the Service on behalf of their child. We are the data controller for the personal data described below.
Accounts are created and controlled by a parent or legal guardian, not by the child. Where this policy refers to "your child's data", it means information you provide about your child, and information generated while your child uses the Service under your account and supervision. We treat this as children's personal data and apply the extra care that requires — see Section 6.
| Category | Examples | Source |
|---|---|---|
| Account data | Parent email address, password (stored as a salted hash, never in plain text) | You, at signup |
| Child profile | Child's first name, year group, target exam date | You, at onboarding |
| Tutoring content | Messages sent to and received from the AI tutor, answers given, questions asked | You and your child, during tutoring sessions |
| Progress data | Scores, diagnostic results, session logs, streaks, programme plan | Generated by the Service as your child uses it |
| Parent progress questions | Questions you ask the parent-facing "ask about progress" assistant, and its answers — this assistant only reads your child's existing scores and programme data; it cannot change them | You, when using the parent progress assistant |
| Billing data | Subscription plan, status, billing dates. Card details are collected and stored by Stripe, not by us. | You, via Stripe Checkout |
| Technical data | IP address, browser type, basic request logs, error reports | Automatically, from your device |
| Feedback | Anything you choose to submit via an error or feedback form | You, optionally |
We do not use your child's data for advertising, and we do not sell personal data.
When your child sends a message in a tutoring session, that message (and recent conversation history, needed for the tutor to hold a coherent conversation) is sent to Anthropic's Claude API to generate the tutor's reply. The same applies when you use the parent-facing "ask about progress" assistant — your question, and your child's existing score/programme data needed to answer it accurately, is sent to the same API. This means tutoring content and parent progress questions are processed by a subprocessor located outside the UK/EEA (the United States); see Section 7 on international transfers.
| Who | What they see | Why |
|---|---|---|
| Anthropic (Claude API) | Tutoring conversation content, and parent progress-assistant questions | Generates the AI tutor's replies and progress-assistant answers |
| Stripe | Billing/payment details, email | Processes subscription payments |
| Render | All data, encrypted at rest and in transit | Hosts the application and database (Frankfurt, EU region) |
We do not share your or your child's data with any other third party, except where required by law, to protect the safety of a child, or with your consent.
We only collect the minimum child information needed to run the tutoring service: a first name, year group, and target exam date, plus the tutoring conversation and progress data generated as your child uses the Service. We do not require or collect your child's date of birth, address, school name, or any other identifying detail beyond what's listed above. Your child's account is not a standalone account — it exists only as a profile under your parent account, which you control and can delete at any time (see Section 8). We do not send marketing communications to children, and we do not use profiling based on a child's data for anything other than adapting their own tutoring difficulty.
Because Anthropic's Claude API is used to generate tutoring replies, some personal data (tutoring conversation content) is transferred to and processed in the United States. Where we transfer personal data outside the UK/EEA, we rely on the UK International Data Transfer Addendum and the EU Standard Contractual Clauses, which are incorporated by reference into Anthropic's Data Processing Addendum and apply automatically to our use of their API, to ensure it receives an equivalent level of protection. By default, Anthropic does not use API inputs or outputs to train their models.
Stripe processes billing and payment data under its own Data Processing Agreement, which incorporates the EU Standard Contractual Clauses and the UK International Data Transfer Addendum by reference through Stripe's Data Transfers Addendum, to ensure an equivalent level of protection for any processing outside the UK/EEA.
We keep account, child profile, and progress data for as long as your account is active, so your child's progress history remains useful to you. If you close your account, we delete this data on request, except where we must keep limited records for legal or accounting reasons. We will act on a deletion request within 30 days of receiving it. Our retention periods are:
| Data | Retention period |
|---|---|
| Account, child profile, tutoring conversations, and progress data | While your account is active; purged when you request deletion |
| Billing records | 6 years from the end of the relevant financial year (a legal minimum under HMRC record-keeping rules for Corporation Tax) |
| Backups | 30–90 days after account deletion, then purged |
If your subscription lapses and is not renewed, we do not delete your account or your child's data immediately — it remains available so your child's progress isn't lost if you come back later in the same academic year. If a lapsed subscription is not renewed within 6 months, we will email you a warning that the account is scheduled for deletion. If we do not hear back within a further 30 days, we will delete the account and your child's data, subject to the same legal/accounting exceptions described above.
Your data is stored in a PostgreSQL database hosted by Render in the Frankfurt (EU) region. Tutoring conversation content is additionally processed in the United States by Anthropic's Claude API to generate replies, under the international-transfer safeguards described in Section 7.
Under UK GDPR, you have the right to:
To exercise any of these rights, contact us at kitchenmargins@gmail.com.
We use industry-standard measures to protect personal data, including encrypted connections (HTTPS), hashed passwords, and access controls on our database. No system is perfectly secure, and we cannot guarantee absolute security, but we work to keep data protected and will notify you if we become aware of a breach affecting your personal data, as required by law.
We use a small number of strictly necessary cookies to keep you logged in and to protect the Service against cross-site request forgery. We do not use advertising or third-party tracking cookies.
We may update this Privacy Policy from time to time. We'll post the updated version here with a new "last updated" date.
PassEleven Ltd, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ — kitchenmargins@gmail.com
This is a draft template, not legal advice. Confirm the international-transfer safeguard actually in place with each subprocessor, and have a qualified solicitor review it before relying on it — particularly given the UK Children's Code (Age Appropriate Design Code) applies to services likely to be accessed by children.