Privacy Policy

About this policy

T5 Interactive Limited (trading as "Trailblaze", "Trailblazelearn.com", "we", "us" or "our") is committed to protecting the privacy and security of your personal information and that of your child.

This Privacy Policy explains how we collect, use, share and protect personal information when you use our website (www.trailblazelearn.com) and our mobile application (together, the "Platform"). It also tells you about your rights and how to contact us.

Company details:

• Company name: T5 Interactive Limited
• Registration number: 16620203 (England and Wales)
• Registered address: T5 Interactive Limited, Angel Court, 81 St Clement’s Street, Oxford OX4 1AW
• Data Protection Officer: dpo@t5i.io

Please read this policy carefully. By using our Platform, you accept the practices described in this Privacy Policy.

Who this policy applies to

Our Platform is designed for children aged 7–11 preparing for school entrance examinations. We recognise that children deserve special protection when it comes to their personal information.

If you are a parent or guardian: You control your child's account and their personal information. This policy explains what information we collect about you and your child, and how we use it.

If you are a child: This service is for you, but your parent or guardian is responsible for your account. If you have any questions about how we use your information, please ask them to contact us.

Information we collect

Information you provide to us

When you create an account:

• Your name (parent/guardian)
• Your email address
• Your child's first name
• Your child's player name (chosen by you or your child)
• Your child's school year
• The entrance examinations your child is preparing for (11+, ISEB Pre-Test, CEM or other)
• The subjects your child wishes to practise

When you subscribe:

• Payment information is collected and processed by our third-party payment processor Stripe. We do not store your complete payment card details on our systems. We receive only confirmation of payment and limited transaction details necessary for billing purposes.

When you contact us:

• Any information you provide when you contact our support team, including the content of your messages

Information we collect automatically

Learning and usage data:

• Your child's answers to questions and quiz performance
• Your child's progress through learning activities
• Ratings and feedback on educational content
• Time spent on activities
• Features used within the Platform
• Device information (device type, operating system, unique device identifiers)
• App version and settings

Website analytics:

• We use Google Analytics on our website to understand how visitors use our site
• This collects information such as pages visited, time on site, browser type and referring website
• You can opt out of Google Analytics tracking using browser plugins or your cookie preferences

App analytics:

• We use PostHog to analyse how the app is used and to improve the user experience
• This includes interaction data, feature usage and technical performance information
• Analytics data is pseudonymised where possible

Technical information:

• IP address (which may indicate approximate location)
• Browser type and version
• Time zone setting and location
• Operating system and platform

Information we do not collect

We do not:

• Allow children to communicate with other users through the Platform
• Collect precise geolocation data
• Require children to provide more personal information than is reasonably necessary to use the Platform
• Use children's personal information for marketing or advertising purposes
• Sell children's personal information to third parties

How we use your information

We use personal information for the following purposes:

To provide and improve the Platform

Parent and account information:

• To create and manage your account
• To process your subscription payments
• To communicate with you about your subscription and account
• To provide customer support
• To send important service updates and notices

Child's learning data:

• To deliver personalised learning experiences adapted to your child's progress and needs
• To track your child's performance and provide you with progress reports
• To identify areas where your child needs additional support or challenge
• To generate insights shown in the parent dashboard
• To improve our adaptive learning algorithms
• To develop and enhance educational content
• To ensure the Platform functions properly

To analyse and improve our service

• To understand how users interact with the Platform
• To test new features and improvements
• To identify and fix technical issues
• To improve the effectiveness of our teaching methods

For research and development

• We may use anonymised and aggregated learning data for educational research purposes
• This may include collaboration with academic partners (such as University of Oxford) to study learning outcomes and pedagogical approaches
• No individual child or family will be identifiable in any research outputs
• Where required, we will seek your explicit consent before using data for specific research projects

Legal and security purposes

• To comply with legal obligations
• To protect the security and integrity of the Platform
• To prevent fraud or misuse
• To enforce our Terms of Service

Legal basis for processing (GDPR)

We process personal information under the following legal bases:

• Contract: To fulfil our contract with you to provide the Platform
• Legitimate interests: To improve the Platform, ensure security and conduct research (where this does not override your rights)
• Consent: Where we have obtained your explicit consent, such as for certain marketing communications or specific research projects
• Legal obligation: Where we are required by law to retain certain information

For children's personal information, we rely primarily on parental consent and our legitimate interest in providing an educational service to your child.

How we share your information

We do not sell your personal information or your child's personal information to anyone.

We share personal information only in the following limited circumstances:

Service providers

We work with trusted third-party service providers who process personal information on our behalf, including:

• Payment processing: Stripe processes subscription payments securely
• Cloud hosting: Our Platform is hosted on secure cloud infrastructure (Supabase, Vercel)
• Analytics: PostHog (app analytics) and Google Analytics (website analytics)
• Customer relationship management: Zoho Desk
• Email delivery: For sending transactional emails and service updates

All service providers are required to:

• Process personal information only on our instructions
• Implement appropriate security measures
• Comply with GDPR and other applicable data protection laws

Academic research partners

With your explicit consent, we may share anonymised, aggregated data with academic research partners to study learning outcomes and improve educational practices. Individual children or families will never be identifiable in shared data.

Legal requirements

We may disclose personal information if required to do so by law or in response to valid requests by public authorities (e.g. a court order or government agency).

Business transfers

If we are involved in a merger, acquisition or asset sale, your personal information may be transferred. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

International data transfers

Some of our service providers may be located outside the United Kingdom and European Economic Area (EEA). When we transfer personal information internationally, we ensure appropriate safeguards are in place, such as:

• Standard contractual clauses approved by the UK Information Commissioner's Office
• Adequacy decisions recognising equivalent data protection standards
• Other lawful transfer mechanisms under UK GDPR

Our primary infrastructure providers (Supabase, Vercel) use data centres that may be located in various jurisdictions. We ensure that all transfers comply with UK data protection requirements.

How we protect your information

We take the security of your personal information seriously and implement appropriate technical and organisational measures, including:

Technical security:

• AES-256 encryption for data at rest
• TLS 1.3 encryption for data in transit
• Secure authentication and access controls
• Regular security testing and monitoring
• Automatic security updates

Organisational security:

• Access to personal information is restricted to authorised personnel only
• Staff are trained on data protection requirements
• Regular review of security practices
• Incident response procedures

Platform-specific protections for children:

• No public profiles or user-generated content visible to other users
• No direct communication between children
• Parental controls over account settings
• Age-appropriate privacy settings by default

While we take extensive precautions, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but will notify you of any breach that is likely to result in a risk to your rights and freedoms.

How long we keep your information

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected or to comply with legal obligations.

Active accounts:

• We retain your account information and your child's learning data for as long as your account remains active

Closed accounts:

• When you close your account, we delete personal information within 12 months, except where we are required to retain certain information for legal or regulatory purposes
• Financial records (payment history, invoices) are retained for up to 7 years to comply with accounting and tax requirements
• Anonymised data may be retained indefinitely for research and product improvement

Analytics data:

• Website analytics data is retained according to Google Analytics retention settings (typically 26 months)
• App analytics data is retained according to PostHog retention settings

You can request deletion of your data at any time (see "Your rights" below).

Your rights

Under UK GDPR and the Data Protection Act 2018, you have the following rights:

Right to access

You can request a copy of the personal information we hold about you and your child. This is commonly known as a "subject access request".

Right to rectification

You can ask us to correct personal information that is inaccurate or incomplete. You can update most information directly in your account settings.

Right to erasure ("right to be forgotten")

You can ask us to delete your personal information and your child's personal information in certain circumstances, such as:

• The information is no longer necessary for the purposes for which it was collected
• You withdraw consent (where consent is the legal basis for processing)
• You object to processing and there are no overriding legitimate grounds

Please note that we may retain certain information where we have a legal obligation to do so (such as financial records).

Right to restrict processing

You can ask us to restrict how we use your personal information in certain circumstances, such as when you are contesting the accuracy of the data.

Right to data portability

You can ask for a copy of personal information you have provided to us in a structured, commonly used, machine-readable format, or request that we transfer it to another service provider.

Right to object

You can object to processing based on legitimate interests or for direct marketing purposes.

Rights related to automated decision-making

Our adaptive learning system uses automated processes to personalise your child's learning experience. This is designed to benefit your child by providing appropriately challenging content. You have the right to request human review of decisions that have a significant effect.

How to exercise your rights

To exercise any of these rights, please contact us at dpo@t5i.io. We will respond to your request within one month.

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) if you believe we have not complied with data protection laws. Visit www.ico.org.uk for more information.

Parental controls and children's rights

As a parent or guardian, you control your child's account and their personal information. You can:

• Access and review your child's personal information
• Correct or update your child's information
• Delete your child's account and personal information
• Withdraw consent for the processing of your child's personal information
• Opt out of certain uses of your child's information (such as research)

You can exercise these rights through your account settings or by contacting us at dpo@t5i.io.

We will never:

• Require your child to disclose more personal information than is reasonably necessary to use the Platform
• Use your child's personal information for marketing or targeted advertising
• Share your child's personal information with third parties for their marketing purposes
• Allow your child to make their personal information publicly available

Cookies and similar technologies

What are cookies?

Cookies are small text files stored on your device when you visit a website. They help websites function properly and provide analytics information.

How we use cookies

Essential cookies:

• These are necessary for the Platform to function
• They include authentication cookies to keep you logged in
• You cannot opt out of essential cookies if you wish to use the Platform

Analytics cookies:

• Google Analytics (website only) helps us understand how visitors use our site
• These cookies collect information such as pages visited and time spent on site
• You can opt out using your browser settings or our cookie preference tool

Performance cookies:

• PostHog analytics helps us improve app performance and user experience
• These cookies collect information about how you interact with the app

Managing cookies

You can control and delete cookies through your browser settings. However, disabling certain cookies may affect the functionality of the Platform.

For more information about managing cookies, visit www.aboutcookies.org.

Third-party links

Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any personal information.

Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational or regulatory reasons.

When we make material changes, we will notify you by:

• Posting the updated policy on our website with a new "Last updated" date
• Sending you an email notification to the address associated with your account
• Displaying a prominent notice within the Platform

Your continued use of the Platform after changes become effective constitutes acceptance of the updated policy.

We will seek fresh consent if we wish to use your child's personal information for a purpose that was not covered by this Privacy Policy at the time you created your account.

Contact us

If you have any questions about this Privacy Policy or our data practices, please contact us:

Data Protection Officer Email: dpo@t5i.io

Company address: T5 Interactive Limited, Angel Court, 81 St Clement’s Street, Oxford OX4 1AW

Regulatory authority: If you are not satisfied with our response, you can contact the UK Information Commissioner's Office:

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Telephone: 0303 123 1113
Website: www.ico.org.uk

Age Appropriate Design Code compliance

This Platform is designed for children aged 7–11 and complies with the UK Age Appropriate Design Code. We have designed the Platform with children's best interests at heart, including:

• Privacy settings are set to "high" by default
• We collect the minimum amount of personal information necessary
• We do not use children's personal information for profiling or targeting, except to provide personalised learning
• We do not share children's personal information for marketing purposes
• We provide prominent, age-appropriate information about privacy
• We have turned off geolocation services by default
• We provide parents with clear controls over their child's account
• We have implemented appropriate security measures

By using the Trailblaze Platform, you acknowledge that you have read and understood this Privacy Policy.