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
| What | Why | Lawful basis (UK GDPR Art. 6) |
|---|---|---|
| Your email address | To 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 teacher | To greet you and word the grown-ups area for you | Contract |
| Your password and recovery code, only as one-way, salted and keyed hashes | To 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 created | To keep you signed in and let you sign out everywhere | Contract |
| Sign-in, sign-up and recovery attempts, recorded against a scrambled (hashed) email and network address, or network address alone, and deleted after 24 hours | To stop people guessing passwords | Legitimate interests (keeping accounts safe) |
| The version of this notice and the terms you agreed to | To show what you agreed to | Legal obligation / legitimate interests |
For each child you add
| What | Why |
|---|---|
| Nickname (we ask you not to use a surname), school year (Reception, Year 1 or 2), chosen world and helper | So 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 choices | To 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)
| # | Standard | How the app meets it |
|---|---|---|
| 1 | Best interests of the child | Short daily missions, gentle streaks with rest days, no ads, no purchases, no loss-aversion. Pedagogy comes before engagement. |
| 2 | Data protection impact assessment | Kept 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). |
| 3 | Age-appropriate application | Child 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. |
| 4 | Transparency | This notice, a child-friendly summary, and plain explanations at sign-up and in Account. |
| 5 | Detrimental use of data | Data is used only to choose practice and show progress. No nudges to play longer. Sibling comparison is off by default. |
| 6 | Policies and community standards | No chat, sharing or user-generated content visible to others. |
| 7 | Default settings | "This device only" is available with no account. Account sync shares nothing with anyone. No optional data collection is switched on by default. |
| 8 | Data minimisation | A nickname and a school year per child; no birthday, surname, school, photo or location. Recordings and photos never leave the device. |
| 9 | Data sharing | None, except Cloudflare as hosting processor. |
| 10 | Geolocation | Not collected. |
| 11 | Parental controls | Grown-ups see all progress openly in the parent zone; children see their own stars and stickers. No covert monitoring. |
| 12 | Profiling | Only the learning engine adapts practice (the core service). No marketing profiling. |
| 13 | Nudge techniques | No dark patterns; fixed, visible rewards; no countdown pressure. The privacy-protective option ("this device only") is presented as clearly as the account option. |
| 14 | Connected toys and devices | Not applicable. The microphone is used only when a grown-up presses Record or for optional reading recordings. |
| 15 | Online tools | Download 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.