Contents
- Data controller
- What data we collect
- Lawful basis for processing
- How we use your data
- Third-party services
- Cookies & consent
- Children's privacy & the Children's Code
- International transfers
- Data retention
- Your rights
- Automated decisions & profiling
- Security
- Changes to this policy
- Contact & complaints
Data controller
The data controller responsible for personal data collected through gcsepython.uk is:
Vantara Educational Services
Suite A | 82 James Carter Road | Mildenhall | IP28 7DE
ICO registration number: ZC105934
What data we collect
We collect only the personal data necessary for the purposes described in this policy (the principle of data minimisation β UK GDPR Article 5(1)(c)).
| Category | Data collected | Source |
|---|---|---|
| Account data | Email address, display name, profile photo URL | Provided by Google OAuth when you sign in |
| Learning progress | Completed units, XP points, earned badges, Quick Fire quiz scores | Generated automatically as you use the site |
| Cookie consent record | Your cookie preferences and the timestamp of your choice | Stored in your browser when you interact with our cookie banner |
| Usage & analytics data Only after analytics consent | Pages visited, features used, session duration, device type, browser type, approximate country/region. IP addresses are anonymised before storage. | Collected automatically by Google Analytics once you consent |
| Advertising data Only after advertising consent | Cookie identifiers used by Google to serve and measure adverts | Set automatically by Google AdSense once you consent |
| No account β local only | If you do not sign in, all progress is stored only in your browser's local storage and is never transmitted to us or any third party | Stored entirely on your own device |
We do not collect sensitive personal data (health data, racial or ethnic origin, political opinions, religious beliefs, biometric data). We do not collect financial information of any kind.
Lawful basis for processing
UK GDPR Article 6 requires us to identify a specific lawful basis for each processing activity we carry out.
| Processing activity | Lawful basis | Justification |
|---|---|---|
| Google Sign-In authentication | Legitimate interests (Art. 6(1)(f)) | Necessary to provide a cross-device learning experience. You can use the site without an account, so our interests do not override your rights. |
| Storing learning progress in Firestore | Legitimate interests (Art. 6(1)(f)) | Core functionality; users reasonably expect progress to persist. Processing is proportionate and minimised. |
| Analytics cookies and usage statistics | Consent (Art. 6(1)(a) & PECR Reg. 6) | Explicit prior consent obtained via cookie banner before Analytics loads. Withdrawable at any time via Cookie Settings in the footer. |
| Advertising cookies and Google AdSense | Consent (Art. 6(1)(a) & PECR Reg. 6) | Explicit prior consent obtained via cookie banner before AdSense loads. Withdrawable at any time via Cookie Settings in the footer. |
| Security monitoring and fraud prevention | Legitimate interests (Art. 6(1)(f)) | Necessary to protect the integrity of the service and the safety of users. |
| Responding to data subject rights requests | Legal obligation (Art. 6(1)(c)) | Required by UK GDPR Articles 12β22. |
| Notifying the ICO of data breaches | Legal obligation (Art. 6(1)(c)) | Required by UK GDPR Article 33. |
How we use your data
We use personal data only for specific, stated purposes and will never use it for a purpose incompatible with why it was collected. We do not sell your personal data to any third party.
- Providing the service β saving and syncing learning progress, XP, and badges across devices when signed in.
- Improving the site β where analytics consent is given, understanding which topics students find difficult to improve content quality.
- Keeping the site free β where advertising consent is given, displaying Google AdSense adverts to fund hosting and development costs.
- Security β detecting and preventing fraudulent or harmful use of the service.
- Legal compliance β responding to lawful requests from regulators, courts, or law enforcement where legally required.
We do not use your data for direct marketing. We do not share data with third parties for their own marketing. We do not carry out automated decision-making with significant effects (see Section 11).
Third-party services
We use the following third-party services. Where they act as data processors on our behalf, we rely on Google's standard Data Processing Addendum as required by UK GDPR Article 28.
| Service | Role | Purpose | Privacy policy |
|---|---|---|---|
| Firebase Auth (Google) | Data processor | User authentication | firebase.google.com/support/privacy |
| Cloud Firestore (Google) | Data processor | Storing learning progress | firebase.google.com/support/privacy |
| Google Analytics | Data processor | Usage statistics β only after analytics consent | policies.google.com/privacy |
| Google AdSense | Independent controller | Serving adverts β only after advertising consent | policies.google.com/technologies/ads |
| Google Fonts | Data processor | Loading Sora and Nunito Sans typefaces | developers.google.com/fonts/faq/privacy |
Cookies & consent
We use cookies in accordance with the Privacy and Electronic Communications Regulations 2003 (PECR). Non-essential cookies are only placed after you give freely given, specific, informed, and unambiguous consent through our cookie banner.
| Type | Set by | Purpose | Consent required? |
|---|---|---|---|
| Essential | Firebase (Google) | Maintaining your signed-in session | No β strictly necessary |
| Functional | gcsepython.uk (localStorage) | Remembering cookie preferences and storing offline progress | No β strictly necessary |
| Analytics | Google Analytics | Anonymous usage statistics to improve the site | Yes β only set after you consent |
| Advertising | Google AdSense | Serving adverts and measuring performance | Yes β only set after you consent |
Children's privacy & the Children's Code
Minimum age: You must be at least 13 years old to create an account. If you are under 13, please use the site without an account β your progress will be saved locally on your device only.
How we meet the 15 standards of the Children's Code:
| Standard | How we comply |
|---|---|
| Best interests of the child | The site's sole purpose is to support GCSE revision. We have considered children's best interests in a documented DPIA. We use no dark patterns or manipulative design. |
| Data protection impact assessments | A DPIA has been completed for this service given that we process children's data at scale. It is reviewed when the service changes materially. |
| Age-appropriate application | Minimum age is 13. Users are actively encouraged to use the site without an account to avoid any personal data collection. |
| Transparency | This policy is written in plain English accessible to teenagers. Key information is presented in tables rather than dense legal text. |
| Detrimental use of data | We do not use children's data in ways detrimental to their wellbeing. We do not sell data, build behavioural profiles, or use data to manipulate children. |
| Policies and community standards | The site contains no user-generated content or social features. Users are not exposed to other users' content. |
| Default settings | Analytics and advertising cookies are off by default. Only strictly necessary cookies fire on first load. Users must actively opt in. |
| Data minimisation | We collect only email address, display name, and progress data β the minimum needed to deliver the service. We do not collect date of birth, phone number, contacts, precise location, or any unnecessary data. |
| Data sharing | We do not share children's data with third parties except as described in Section 5. We never share data for third-party marketing. |
| Geolocation | We do not request or use precise geolocation data. Google Analytics may record approximate country/region only, and only with consent. |
| Parental controls | Parents or guardians may request deletion of a child's account and all associated data by emailing hello@gcsepython.uk. We will action such requests within 5 working days. |
| Profiling | We do not profile children for advertising or any other purpose. No user is targeted with personalised advertising based on their behaviour on this site. |
| Nudge techniques | We do not use design techniques that encourage children to share more data than necessary, weaken privacy settings, or extend time on site in harmful ways. Gamification (XP, badges) is used only to motivate learning. |
| Connected toys and devices | Not applicable β this is a browser-only web service. |
| Online tools | Not applicable β the site does not provide tools for generating user content or social interaction. |
Advertising and children: The ICO has stated that behavioural advertising targeting children is incompatible with the Children's Code. We address this specifically: AdSense only loads after a user actively enables advertising cookies in the cookie banner (which is off by default). AdSense is configured to serve non-personalised ads only, meaning ads are targeted at page content, not individual user profiles.
Parental or guardian concerns: If a parent or guardian believes their child has created an account without appropriate consent, contact hello@gcsepython.uk and we will delete the account and all associated data within 5 working days.
International transfers
Data processed by Google services (Firebase, Analytics, AdSense, Fonts) may be transferred to and stored on servers in the United States and other countries outside the UK.
Google LLC participates in the UKβUS Data Bridge (approved by the UK Secretary of State on 12 October 2023), which provides an appropriate safeguard for such transfers as required by UK GDPR Article 46. You can review Google's transfer commitments in their Privacy Policy and Data Processing Addendum.
Data retention
We retain personal data only for as long as necessary for the purpose for which it was collected (UK GDPR Article 5(1)(e)).
| Data type | Retention period | How to delete |
|---|---|---|
| Account data and learning progress | Until your account is deleted | Email hello@gcsepython.uk. Data removed within 30 days. |
| Cookie consent record | Until you clear your browser's local storage | Clear localStorage in your browser settings, or update preferences via Cookie Settings in the footer. |
| Local progress (no account) | Until you clear your browser's local storage | Use "Reset My Progress" on the site, or clear localStorage via browser settings. |
| Google Analytics data | 14 months (Google's minimum retention period) | Withdraw analytics consent via Cookie Settings. Previously collected anonymised data cannot be deleted from Google's servers individually. |
| Google AdSense advertising cookies | Governed by Google β typically up to 13 months | Withdraw advertising consent via Cookie Settings, or delete cookies in your browser. |
Your rights
Under UK GDPR Chapter III, you have the following rights. Rights may be limited in specific circumstances, for example where we have a competing legal obligation to retain data.
Right of access (SAR)
Request a copy of the personal data we hold about you in a commonly used electronic format.
Right to rectification
Ask us to correct inaccurate or complete incomplete data without undue delay.
Right to erasure
Request deletion of your personal data where there is no overriding reason to retain it.
Right to restriction
Ask us to suspend processing while accuracy is disputed or where processing is unlawful.
Data portability
Receive data you provided to us in a structured, machine-readable format (applies to consent-based processing).
Right to object
Object to processing based on legitimate interests at any time. We do not conduct direct marketing.
Withdraw consent
Withdraw consent at any time without affecting the lawfulness of prior processing. Use Cookie Settings in the footer.
Automated decisions
Not to be subject to solely automated decisions with legal or significant effects. We do not make such decisions (see Section 11).
To exercise any right, email hello@gcsepython.uk with the subject line "Data Rights Request". We will respond within one calendar month (UK GDPR Article 12(3)), and may ask you to verify your identity. No charge applies unless a request is manifestly unfounded or excessive.
ico.org.uk/make-a-complaint Β· 0303 123 1113
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
We would always appreciate the opportunity to resolve concerns directly before a complaint is made to the ICO.
Automated decisions & profiling
We do not carry out automated decision-making that produces legal or similarly significant effects on individuals (UK GDPR Article 22). We do not create profiles of users for advertising, credit, employment, insurance, or any other significant purpose.
The site automatically calculates XP totals and awards badges based on your learning activity. This is an integral feature of the revision tool and has no legal or significant real-world effect on you.
Security
We implement appropriate technical and organisational measures to protect personal data (UK GDPR Article 32), including:
- All data is transmitted over HTTPS/TLS β connections are encrypted in transit.
- Authentication and data storage are handled by Firebase (Google Cloud), which is ISO 27001 certified, SOC 2 Type II compliant, and independently audited.
- We do not store passwords β authentication is handled entirely through Google's OAuth 2.0 system.
- Access to production systems and the Firebase console is restricted to the data controller only.
In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours and notify affected individuals without undue delay where required by UK GDPR Article 34.
If you discover a potential security vulnerability, please report it to hello@gcsepython.uk.
Changes to this policy
We may update this policy from time to time. When we do, we will update the "Last updated" date at the top of this page. For material changes that affect how we process your personal data or reduce your rights, we will notify registered users by email at least 14 days before the change takes effect.
Where a material change requires fresh consent, we will seek that explicitly rather than relying on existing consent or continued use of the site. Previous versions of this policy are available on request by emailing hello@gcsepython.uk.
π¬ Contact & complaints
For questions about this policy, to exercise your rights, or to raise a concern, please contact us. We aim to respond within 5 working days.
hello@gcsepython.uk