Privacy Policy — Halomath

Effective date: 10 August 2026 Last updated: 10 August 2026

This Privacy Policy explains how HALOMATH LTD ("Halomath", "we", "us") collects and uses personal data when you and your child use the Halomath app and website at halomath.net (the "Service").

We built Halomath for children, so protecting children's data is central to how we design the product. We follow the UK GDPR, the Data Protection Act 2018, and the ICO's Children's Code (Age Appropriate Design Code). The best interests of the child come first in every design decision.

Quick answers

Most parents want to know three things before they read anything else. Here they are.

Do you use my child's work to train AI models?

No. Not ours, not anyone else's. We call this our Zero Training Promise — see §7.

Do you sell my child's data, or show them adverts?

No, and no. We have never done either and we do not intend to. There is no advertising in Halomath at all.

Does my child get compared or ranked against other children?

No. There are no leaderboards, no rankings, and no class comparisons in the product. Nothing your child can share shows how they compare with anyone else.

And you can ask us to delete everything, at any time — §12.

🧒 For children: We keep your maths safe. We never show you adverts, we never sell your information, and we never show other children how you're doing.

1. Who we are (Data Controller)

The data controller is HALOMATH LTD, a company registered in England & Wales, company number 17294004.

• Contact (including privacy questions and data requests): hello@halomath.net

2. Who uses Halomath

Halomath is set up and managed by a parent or guardian, for a child to practise maths. The parent creates and controls the account; the child practises within it. Children do not create their own accounts, and we do not market to children.

We treat every learner profile as a child's account and apply child-appropriate protections to all of them, rather than trying to guess anyone's age.

🧒 For children: A grown-up sets this up for you. They're always in charge of your account, and they can see how you're getting on.

3. What data we collect

From the parent (account holder):

• Name and email address
• Account login credentials (passwords are stored hashed, never in plain text)
• Payment information — handled by Stripe; we never see or store full card numbers
• Messages you send us (support, onboarding calls, interview notes)

About the child (entered and managed by the parent):

• First name or a nickname — we do not require a full legal name
• School year group or age — used only to pitch the maths at the right level
• Learning data: answers given, questions attempted, which maths concepts are mastered, time spent practising, progress over time
• Working submitted to the in-app helper, where used

Collected automatically (technical):

• Device type, operating system, browser, app version
• Error and performance logs
• The minimum usage data needed to run and fix the Service

We practise data minimisation: we collect what the Service genuinely needs in order to teach, and no more.

We do not collect a child's photograph, voice recording, precise location, home address, phone number, contacts, or school name. We do not ask for them, and there is nowhere in the product to enter them.

🧒 For children: We know your first name (or a nickname you pick), your school year, and the maths you do. That's it. We don't know where you live or what school you go to.

4. Why we use it, and our lawful basis (UK GDPR Article 6)

Where we rely on consent, the parent gives it and can withdraw it at any time without losing access to the core Service.

Because the parent holds the account and agrees to the terms on the child's behalf, parental involvement is built into the product rather than bolted on.

5. What we will NEVER do with a child's data

• ❌ We do not use your child's work to train AI models — ours or anyone else's. See §7.
• ❌ We do not show third-party advertising to children — or to you.
• ❌ We do not sell, rent, or trade personal data. Not now, not later.
• ❌ We do not use a child's data for behavioural or targeted advertising.
• ❌ We do not profile children except as strictly needed to teach them maths at the right level.
• ❌ We do not use nudge techniques, penalty streaks, leaderboards, or push notifications to keep a child on longer than is good for them. The product deliberately ships without them.
• ❌ We do not ask for more personal data than the learning function needs.

6. High privacy by default

Learner profiles are set to the most privacy-protective settings by default. Any optional feature that uses more data stays off until a parent turns it on. Anything a child can share is stripped of comparative and ranking information before it leaves the app.

7. How we use AI — and our Zero Training Promise

Halomath uses AI to help assess level, adapt exercises, and generate progress reports. When this happens, the relevant maths content and the child's working may be sent to Google (Gemini API) solely to generate that output, and then returned to you.

Our Zero Training Promise

We do not use your child's answers, working, progress data, or anything else they produce in Halomath to train, fine-tune, or improve any AI model.

This has two halves, and both matter:

• We don't do it ourselves. We do not train or fine-tune our own models on your child's data. There is no opt-in for this, because we are not asking.
• Our AI provider doesn't do it either. We use a Google service tier that is contractually committed not to use your content to train their models.

Your child's data is used to teach your child, and for nothing else.

If this ever needs to change, we will not do it quietly: we would tell you by email before any change took effect, and it would require your active agreement — not a silent policy update.

The limits of AI, honestly

We send the minimum needed, and avoid attaching identifying details to that content. But we would rather tell you the truth than oversell it:

• AI-generated reports are a teaching aid, not a formal educational, psychological, or clinical assessment.
• AI can be wrong. It can misread a child's working or draw a conclusion that does not match what you see at the kitchen table. Use your own judgement — you know your child better than any model does.
• When something looks off, please tell us. We would genuinely rather hear it.

🧒 For children: A computer helps pick your maths questions and write your report. It only looks at your maths to help you — it never learns from your work to teach anybody else. And sometimes it gets things wrong, so tell a grown-up if something looks odd!

8. Who we share data with (Processors)

We use a small number of service providers ("processors") who act only on our written instructions under a data processing agreement:

We do not sell personal data to anyone. We share data with authorities only where the law requires it, and we will tell you unless we are legally barred from doing so.

9. Where data is stored, and international transfers

We store and process data in the UK or EEA where we can. Some of the providers above process data in the United States. Where that happens we rely on a UK-approved safeguard — the UK International Data Transfer Addendum to the EU Standard Contractual Clauses, and/or the provider's certification under the UK Extension to the EU–US Data Privacy Framework — so your data keeps an equivalent level of protection.

10. How long we keep it

Anonymised, aggregated statistics that can no longer identify anyone (for example "83% of exercises were completed") may be kept and used to improve and describe the Service.

11. How we protect it

We use encryption in transit and at rest, access controls, and hashed passwords. Access to children's data is limited to what is genuinely needed to run the Service. If a personal data breach occurs and it presents a risk, we will report it to the ICO within 72 hours and tell affected parents without undue delay.

12. Your rights (and your child's)

You can, at any time, ask us to:

• Access the personal data we hold
• Correct anything inaccurate
• Delete it (the "right to erasure")
• Restrict or object to certain processing
• Give you a copy in a portable format
• Withdraw consent where we relied on it

The parent exercises these rights on the child's behalf; an older child may also contact us directly, and we will handle it together with the parent.

To make a request, email hello@halomath.net. We respond within one month, free of charge. You can also complain to the ICO (ico.org.uk, 0303 123 1113) — though we would genuinely appreciate the chance to put it right first.

13. Cookies and similar technologies

We use strictly necessary cookies only — the ones that keep you signed in and keep the site secure. These do not require consent. We do not currently use advertising or third-party analytics cookies. If we ever add non-essential analytics, we will ask for your consent first, and you will be able to say no.

14. Changes to this policy

If we make significant changes we will tell you by email and in the app before they take effect. Previous versions are available on request.

15. Contact

HALOMATH LTD · Company number 17294004 · Registered in England & Wales hello@halomath.net

Halomath and your information — the simple version

Hi! Here's how Halomath looks after your information. 🌟

What we know about you

• Your first name, or a nickname you pick
• Your school year, so we can find maths that's just right for you — not too easy, not too hard
• The maths you do here, so we can help you get better at it

What we do with it

• We use it to make your maths fit you.
• We show your grown-up how you're getting on, so they can cheer you on. 🎉

Our promises to you

• 🚫 We will never show you adverts.
• 🚫 We will never sell your information to anyone.
• 🚫 There is no leaderboard here. We will never show other children how you are doing.
• 🤖 The computer helper never learns from your maths to teach other people. Your work is just for you.
• 🤫 Your information is kept safe and private.
• 😊 We won't try to trick you into staying longer, or into telling us things we don't need.

You're in charge

• You and your grown-up can ask us to show you what we know, fix it, or delete it — any time.
• Just ask your parent or carer, and they can email us at hello@halomath.net.

If any of this is confusing, ask a grown-up to read the big version with you. 💙