Privacy Policy

Privacy Policy

Effective Date: 6 July 2026

Everybodycounts Ltd, trading as Everybody Counts ("we," "us," "our"), is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Primary/KS1-KS2 maths learning platform (the "Platform"), including our AI-personalised learning features.

Registered Office: 5–7 Montgomery Lane, Edinburgh, Scotland, EH7 5JT.

1. Information We Collect

We collect the following types of information:

1.1 Personal Data

1. Students: names, ages, school details, class/year group, and educational progress.
2. Teachers and Staff: names, contact information, and professional details.
3. Parents/Guardians: names and contact information.

1.2 Usage Data

1. Information on how the Platform is accessed and used.
2. Technical data such as IP address, browser type, device type, and usage logs.

1.3 Learning Interaction Data (AI-Personalised Learning)

To power our AI-personalised learning features, the Platform records detailed interaction data as a student completes activities, including response accuracy, response timing, answer-revision patterns, navigation behaviour, and error types. This data is used to adapt content difficulty, pacing, and presentation to each student's learning needs.

A subset of this interaction data is analysed by our personalisation models to identify patterns that may be associated with neurodivergent learning traits (for example, patterns commonly associated with dyslexia or dyscalculia). We refer to this as "Inferred Learning Trait Data." This data reflects statistical patterns in how a student interacts with the Platform, not a clinical or medical assessment, and it is never presented to teachers, parents, or students as a diagnosis. This is a core governance principle of our platform: inferred is never treated as diagnosed.

2. How We Use Your Information

2.1 Provision of Services

1. To provide, maintain, and improve our educational services.
2. To manage user accounts and provide customer support.

2.2 AI-Personalised Learning

1. To personalise learning experiences, content, and resources for individual students.
2. To adapt pacing, content format, and support materials based on identified learning patterns, including Inferred Learning Trait Data, in order to better support students who may benefit from adjusted teaching approaches.
3. To provide teachers with aggregated, anonymised insights into class-wide learning patterns to support lesson planning.

Our personalisation features are subject to a "fairness firewall": Inferred Learning Trait Data is used only to adapt the learning experience within the Platform, is logically and technically separated from a student's core academic record, and is never used to restrict a student's access to content, lower expectations of a student, or make any decision with a legal or similarly significant effect on a student.

2.3 Communication

1. To communicate with you regarding updates, notices, and administrative messages.

2.4 Compliance and Protection

1. To comply with legal obligations and enforce our terms and conditions.
2. To protect the rights, property, and safety of users and others.

3. Legal Basis for Processing

We process personal data based on:

1. Consent: where we have obtained explicit consent from the user, their school, or their parent/guardian.
2. Contractual Obligations: to fulfil our contractual obligations with schools and educational institutions.
3. Legal Compliance: to comply with legal and regulatory requirements.
4. Legitimate Interests: for legitimate business interests, such as improving our services, provided these interests are not overridden by the interests or fundamental rights of the student.

3.1 Special Category Data

Inferred Learning Trait Data, because it relates to indicators that may be associated with neurodiversity, is treated by us as data concerning health for the purposes of UK GDPR. We only generate and use this data where the student's school has enabled the relevant AI personalisation features on the school's behalf under its data protection agreement with us, and, where required by applicable law or the school's own policies, parental/guardian consent has also been obtained. This dual consent gating ensures Inferred Learning Trait Data is never processed without an appropriate lawful basis under Article 9 UK GDPR, which in this context is explicit consent.

4. Automated Processing and Profiling

Our AI-personalisation features involve automated analysis of a student's interaction data. We do not use this analysis to make any decision about a student that produces legal effects or similarly significant effects without meaningful human involvement. Specifically:

1. Any content or pacing recommendations made by our personalisation engine can be reviewed, overridden, or switched off by a school administrator.
2. Inferred Learning Trait Data is never used to make decisions about assessment results, academic records, or a student's progression.
3. Schools may request the disabling of AI-personalised learning features for their school at any time, without affecting the student's access to the core Platform. However, where a school disables AI data collection, we reserve the right to revisit the commercial terms of the school's subscription accordingly.

5. Data Sharing and Disclosure

We may share your information with:

1. Educational Institutions: schools and educational bodies that use our services.
2. Service Providers: third-party service providers who perform functions on our behalf, currently Google Analytics and Amazon Web Services, bound by data processing agreements.
3. Legal Authorities: if required by law, to comply with legal processes or protect our rights.

We do not sell personal data, and we do not share Inferred Learning Trait Data with any third party for marketing, advertising, or profiling purposes unrelated to the delivery of the Platform.

6. Data Security

We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include:

1. Secure data storage.
2. Encryption of sensitive information, both in transit and at rest.
3. Access controls and authentication mechanisms, including role-based access restrictions limiting who can view Inferred Learning Trait Data.
4. Logical separation of Inferred Learning Trait Data from core academic and assessment records.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including any legal or reporting requirements. Once data is no longer needed, we securely delete or anonymise it. Inferred Learning Trait Data is retained only for as long as the relevant AI personalisation features remain active for a student, and is deleted or anonymised on a rolling basis as it is superseded by more recent interaction data, or on request from the school or parent/guardian.

8. Children's Privacy

Protecting the privacy of children is especially important. We collect personal data from children aged 5 to 11 only with the consent of their school and, where applicable, their parents or guardians. We design our Platform in line with the principles of the ICO's Age Appropriate Design Code, including high privacy-by-default settings, data minimisation, and no use of children's data for advertising or marketing. We encourage parents and schools to monitor children's use of our services.

9. Your Data Protection Rights

You have the following rights regarding your personal data:

1. Access: the right to request access to your personal data.
2. Rectification: the right to request correction of inaccurate data.
3. Erasure: the right to request deletion of your personal data under certain conditions.
4. Restriction: the right to request restriction of processing of your personal data.
5. Data Portability: the right to receive your personal data in a structured, commonly used, and machine-readable format.
6. Objection: the right to object to the processing of your personal data, including profiling carried out as part of AI-personalised learning.
7. Automated Decision-Making: the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects, and the right to request human review of any such decision.

10. Contact Us

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

Email: privacy@everybodycounts.org.uk

Address: 5–7 Montgomery Lane, Edinburgh, Scotland, EH7 5JT

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We encourage you to review this Privacy Policy periodically for any updates.

By using our services, you agree to the collection and use of information in accordance with this Privacy Policy.