Privacy notice — ADHIYA & AMIYA Learning Centre

Last updated 6 November 2026 (version 2026-10-29). This page explains, in plain English, what we keep, why, where, for how long, and how to see, take or delete it. It is written to follow UK GDPR, the Data Protection Act 2018 and the ICO Age Appropriate Design Code (the "Children's Code").

The short version (read this to your child)

> We only know your nickname, the character you made and how your learning is going, so the app can choose good > games for you. We never show it to anyone else. Your grown-up can see it and can delete it whenever they like.

The short version for grown-ups

  • No ads, no tracking, no analytics, no selling or sharing data. There are no third-party scripts in the app.
  • Only grown-ups have accounts. Children never type an email or a password. A child is just a nickname, a cartoon character and their learning progress.
  • You can use the app without an account ("Use on this device only"). Then nothing about you or your children leaves your device at all.
  • You're in control: download everything, or delete your account and everything in it, from Grown-ups → Account.

Who we are

ADHIYA & AMIYA Learning Centre (opziro.shop) is a free learning app and a product of OPZIRO LTD, which is the data controller for accounts. "We" and "us" on this page means OPZIRO LTD. We are registered with the Information Commissioner's Office (ICO), registration reference ZC289840.

  • Company: OPZIRO LTD, registered in England and Wales, company no. 17551076
  • Registered office: 209 The Heights, Northolt, England, UB5 4BX
  • Email: info@opziro.com
  • Website: https://www.opziro.com
  • ICO registration reference: ZC289840

To contact us about privacy, email info@opziro.com, or use the contact form on the front page and choose "Privacy and data".

What we keep, and why

If you create a grown-up account

WhatWhyLawful basis (UK GDPR Art. 6)
Your email addressTo sign you in. We don't send marketing or newsletters.Contract (to provide your account)
Your first name and whether you're a parent, guardian or teacherTo greet you and word the grown-ups area for youContract
Your password and recovery code, only as one-way, salted and keyed hashesTo check it's you. We can never see or tell you your password.Contract
Signed-in devices: a random session code (stored only as a hash), a label such as "Safari on iPad", and when it was createdTo keep you signed in and let you sign out everywhereContract
Sign-in, sign-up and recovery attempts, recorded against a scrambled (hashed) email and network address, or network address alone, and deleted after 24 hoursTo stop people guessing passwordsLegitimate interests (keeping accounts safe)
The version of this notice and the terms you agreed toTo show what you agreed toLegal obligation / legitimate interests

For each child you add

WhatWhy
Nickname (we ask you not to use a surname), school year (Reception, Year 1 or 2), chosen world and helperSo the app can greet them and pitch the learning right
Which character they chose from our ready-made gallery (stored as a short code such as “c07”)Only to show their character. It is never analysed and never used to guess anything about your child; any child may choose any character.
Learning progress: which sounds, letters, numbers and facts they know, their answers and timings, stars, stickers, medals, exam and mock-check results, daily plan, and dress-up studio choicesTo choose the right practice and show you how they're doing
Your settings (phonics programme, mission length, sound effects and similar)So every family device works the same way

This is processed under contract with you, the grown-up account holder, to provide the learning service you asked for. We never ask for a child's date of birth, full name, school, address, photo, location or contact details.

Things that never leave your device

Voice recordings you make in Record my voice, your child's reading recordings, and photo-booth pictures are kept only on the device where they were made, even with an account.

Where your data is kept, and who helps us

Accounts, children's profiles and progress are stored in a Cloudflare D1 database, and the app is served by Cloudflare (Cloudflare, Inc. and its group companies), which acts as our processor under its data processing terms. Cloudflare runs a global network, so data may be processed outside the UK; transfers are covered by Cloudflare's data processing addendum with the UK International Data Transfer Addendum and EU Standard Contractual Clauses. No one else receives your data, and we never sell it.

When you choose a new password, our server checks it against the Have I Been Pwned list of breached passwords. It sends only the first 5 characters of a scrambled (hashed) version of the password: never the password, your email or anything that identifies you.

How long we keep it

  • Your account and your children's data: until you delete the child or the account. Deleting is immediate. Database backups that may still hold it are overwritten within 30 days.
  • Accounts nobody has signed in to for 2 years are deleted automatically with everything in them.
  • Sign-in sessions end after 30 days without use, and after 90 days at most.
  • Sign-in attempt records: 24 hours.
  • "This device only" data stays on your device until you delete it (Grown-ups → Privacy & data) or clear your browser's data.

Your rights

You can, at any time and for free:

  • See and download all your data: Grown-ups → Account → Download my data (a JSON file).
  • Correct it: change names, years and characters in Grown-ups → Children, and your name in Account.
  • Delete a child (Children → Remove) or your whole account (Account → Delete account).
  • Object to or restrict processing, or ask us anything about your data, using the contact form.

You can also complain to the Information Commissioner's Office (ico.org.uk, 0303 123 1113). We'd appreciate the chance to put things right first.

Cookies and storage

We use one cookie, which is strictly necessary: a secure, HTTP-only sign-in cookie (__Host-aa_sid) that keeps a grown-up signed in. The app also stores its learning data and offline files in your browser (IndexedDB, local storage and the offline cache) so it works without the internet. None of this is used for advertising or tracking, so there is no cookie banner.

Teachers and schools

Teachers can add pupils using nicknames, in the same way as parents. If your school wants to use the app under a school agreement, please contact us first so we can agree how the data is handled (a data processing agreement).

Security

Passwords are salted, peppered and hashed with PBKDF2; session codes and recovery codes are stored only as hashes; every connection is encrypted (HTTPS); sign-in attempts are rate-limited; and the grown-ups area of the app is behind a parent gate. If something ever goes wrong, we'll tell affected account holders and the ICO as the law requires.

Changes

If we change how we use data, we'll update this page and its version date, and ask you to agree again where needed.

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Appendix: Children's Code checklist and DPIA summary (for reviewers)

#StandardHow the app meets it
1Best interests of the childShort daily missions, gentle streaks with rest days, no ads, no purchases, no loss-aversion. Pedagogy comes before engagement.
2Data protection impact assessmentKept in docs/compliance/dpia.md (with the record of processing, breach plan and processor list in docs/compliance/). Risks: account takeover (15+ character passwords, pepper, rate limits, HttpOnly cookies), shared devices (parent gate, sign-out wipes the device), data breach (minimal data, hashes only, no child identifiers), special-category inference from avatar options (stored as opaque codes, never analysed).
3Age-appropriate applicationChild screens are for 4–6s: icons and voice, no text forms, no external links. Accounts, settings and data tools are adult-only, behind the parent gate.
4TransparencyThis notice, a child-friendly summary, and plain explanations at sign-up and in Account.
5Detrimental use of dataData is used only to choose practice and show progress. No nudges to play longer. Sibling comparison is off by default.
6Policies and community standardsNo chat, sharing or user-generated content visible to others.
7Default settings"This device only" is available with no account. Account sync shares nothing with anyone. No optional data collection is switched on by default.
8Data minimisationA nickname and a school year per child; no birthday, surname, school, photo or location. Recordings and photos never leave the device.
9Data sharingNone, except Cloudflare as hosting processor.
10GeolocationNot collected.
11Parental controlsGrown-ups see all progress openly in the parent zone; children see their own stars and stickers. No covert monitoring.
12ProfilingOnly the learning engine adapts practice (the core service). No marketing profiling.
13Nudge techniquesNo dark patterns; fixed, visible rewards; no countdown pressure. The privacy-protective option ("this device only") is presented as clearly as the account option.
14Connected toys and devicesNot applicable. The microphone is used only when a grown-up presses Record or for optional reading recordings.
15Online toolsDownload my data, Delete child, Delete account and Sign out everywhere are in Grown-ups → Account, one tap away.

Lawful basis. Contract with the adult account holder (Art. 6(1)(b)); this is not a consent-based service, so the Art. 8 child-consent rule does not apply. Security records: legitimate interests (Art. 6(1)(f)). Data protection fee. The controller, OPZIRO LTD, has paid the ICO data protection fee and is on the ICO register of fee payers: registration reference ZC289840, registered 1 November 2026, renewal due by 31 October 2027. Parent gate. A random two-digit × one-digit sum or "type the number written in words", with an on-screen number pad; three wrong answers lock it for 30 seconds; an unlock lasts 10 minutes.

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