Last updated 24 September 2026. This notice describes how Kiplrn handles personal data. It is written to match what the product actually does today. If we change how the product works, we will change this notice before the change ships, not after.
Who we are
Kiplrn is operated by Keith Farrugia, a sole trader established in Malta, trading as Kiplrn and MindCore AI. For the purposes of the EU and UK General Data Protection Regulation, he is the data controller.
Address: Antonio Galea Street, Birkirkara, Malta.
Contact for any privacy question or request: support@kiplrn.com.
The important thing first
You do not need an account, and by default we hold nothing about your child. When you set up a profile, it is written to your own browser on your own device — first name, age, avatar, language, parent PIN, and progress. We never receive a copy of any of it.
You can choose to create an account so that progress survives a lost phone or a cleared browser. That is a decision you make deliberately, in Parent Settings, after reading a screen that says plainly what will be stored. Until you do, nothing changes: no account is created, no data is uploaded, and the code that talks to our database is never even loaded by your browser.
Children never sign in and never have accounts of their own. The account is yours.
What data is involved, and where it goes
1. Data stored on your device
The app writes to your browser’s local storage: your child’s first name, age, avatar choice, teaching language, the parent PIN, daily time settings, and a record of sessions, XP and streaks. If you have no account, this stays on the device, and clearing your browser data deletes it permanently and irreversibly.
2. Data stored in your account — only if you create one
If you turn on saved progress, we store a copy of the following so it can reach your other devices:
- For each child: first name, age, avatar, teaching language, the parent PIN, daily goal, school country, school year and programme where you have set them, and their learning record — XP, streaks, badges, flashcards, review schedule, and a per-session summary (subject, topic, mode, duration, XP earned, number of messages).
- For you: your email address, and the times you signed in.
We still do not store what your child actually types to the tutor, or what the tutor replies. The session record says that a 20-minute Maths lesson on fractions happened and earned 40 XP. It does not contain the conversation.
This data is held using Google’s Firebase platform. Your children’s profiles and learning records are stored in the European Union (Google Cloud region europe-west1, Belgium), and access is restricted at the database itself so that one account can only ever reach its own data.
One honest exception: the sign-in record that identifies you — your email address and sign-in timestamps — is held by Firebase Authentication, which Google operates from the United States. That is a transfer of your personal data outside the EEA, not your child’s. Google acts as our processor under its Cloud Data Processing Addendum and the European Commission’s Standard Contractual Clauses.
3. Billing data, if you subscribe
Kiplrn has a free plan and a paid Family plan. If you subscribe, the payment is handled by Stripe Payments Europe, Ltd., which acts as an independent controller of your payment data as well as our processor for the subscription.
We never see or store your card number. Card details are entered on Stripe’s own payment page, not ours, and never reach our servers.
What Stripe receives from us: your email address, an internal account identifier, and which plan you chose. What Stripe sends back to us, and what we store against your account: whether the subscription is active, its status, when it next renews, and Stripe’s own customer and subscription identifiers. Nothing else — no card number, no expiry date, no billing address.
Stripe may collect a billing address and tax status from you directly in order to charge the correct VAT, and processes your data under its own privacy policy. Stripe is based in Ireland; its group operates internationally and transfers are covered by its own safeguards.
Cancelling, changing your card, and downloading invoices all happen in Stripe’s billing portal, reached from inside the app. Children are never shown anything to do with payment — billing sits behind the parent PIN.
4. Photographs of schoolwork — only when you take one
You can photograph a term plan, worksheet or textbook contents page so the tutor knows what your child is covering in class. This is optional, and nothing happens unless you choose it.
When you do: the photo is reduced in size on your own device, sent to our AI provider to read the topic names off it, and then discarded. We do not store it, it is never saved to your account or your device, and it is not written to any log. Only the list of topic names is kept, and you can see and edit that list before saving it.
The model is instructed to return school topic names only, and never to output a person’s name, a school’s name, or anything else identifying that happens to be visible in the picture.
Two things worth being straightforward about. The photograph is processed by an AI provider in the United States, so it leaves the EEA for as long as it takes to read. And a photograph of schoolwork can contain your child’s name or their school’s name whether or not we ask for it. That is why the app tells you, before the camera opens, to photograph the topic list rather than your child’s work, and to cover any names. If you would rather not, type the topics in instead — it works exactly the same.
5. Data sent to AI providers to generate a reply
When your child sends a message, we transmit to an AI provider: their first name, age, chosen language, the subject and topic, and the messages in that conversation. Nothing else. We do not ask for and therefore cannot send a surname, address, school name, email address, telephone number or photograph.
Our providers are Anthropic PBC (Claude models) and Google LLC (Gemini models). Both are located in the United States, so this involves a transfer of personal data outside the EEA. Each processes the data under its own published API terms and retains it for its own limited periods; we do not permit either to use it to train models under those terms.
6. Operational logs
Our hosting provider, Vercel Inc., records standard server logs for requests to our API: timestamp, IP address, and any technical error. Conversation content is not written to these logs. Vercel retains them for a limited period under its own policy.
7. This website
kiplrn.com uses Google Analytics to count visits and understand which pages are useful. This is the marketing site only — it is separate from the app and involves no child data. The app carries no analytics, advertising or third-party tracking.
Why we are allowed to process it (legal basis)
- Providing the tutoring service — performance of a contract with the parent or guardian who set up the profile, and our legitimate interest in operating the service they asked for.
- Storing your children’s profiles and progress in an account — your consent, given on the screen shown before anything is uploaded. You can withdraw it at any time by deleting your account, which erases the stored copy. Withdrawing does not stop you using Kiplrn; it returns you to storing everything on your own device.
- Taking payment and managing your subscription — performance of your contract with us, and compliance with our legal obligations on tax and accounting records.
- Keeping the service running and secure — legitimate interest (server logs, error diagnostics).
- Website analytics — consent, given through the cookie banner on kiplrn.com. You can decline and the site works normally.
Children
Kiplrn is designed for children aged 4 to 15 and is intended to be set up and supervised by a parent or guardian. A child should not create a profile on their own. By setting one up, and again before any data is stored in an account, you confirm you are the parent or guardian of that child and consent to the processing described here.
We minimise children’s data by design: we ask for a first name because a tutor that uses a child’s name teaches better, and an age because the tutor must pitch its language correctly. We ask for nothing else, and the tutor is instructed never to request identifying details and never to repeat them back if a child volunteers them.
Children are given no credentials of any kind. There is no child login, no child email address, and no way for a child to sign in anywhere. Nothing to do with payment is ever shown to a child.
How long we keep things
- Your child’s profile and progress, with no account — on your device, until you clear it. We hold no copy.
- Your child’s profile and progress, with an account — for as long as your account exists. Deleted immediately and permanently when you delete your account.
- Dormant accounts — if nobody signs in for 24 months, we email you, and if there is no response within 30 days we delete the account and everything in it.
- Subscription and payment records — retained for as long as tax and accounting law requires, which in Malta is several years. These are held by Stripe and in our own billing records. They survive account deletion, because we are obliged to keep them; they contain no card number and no child data.
- Photographs of schoolwork — not retained at all. Read once and discarded; only the topic names you save are kept.
- Conversation content — not retained by us at all. Held briefly by the AI provider under its own terms.
- Server logs — retained by our host for a limited period, then discarded.
- Website analytics — per Google Analytics retention settings, currently 14 months.
Your rights
Under the GDPR you have the right to access, correct, erase, restrict and object to the processing of personal data, and the right to data portability.
If you have no account, there is normally nothing for us to produce or erase — those controls sit in your own browser, and clearing your site data exercises them completely.
If you have an account, you do not need to write to us and wait. In the app, open Parent Dashboard → Account & data:
- Download all my data gives you everything we hold, as a file, immediately.
- Delete my account and all data permanently erases every child profile, session record and certificate we hold. It is immediate and it cannot be undone. Note that if you have an active subscription you should cancel it first, and that billing records we are legally required to keep are not erased by this.
If anything does not work, or you believe we hold something we should not, write to support@kiplrn.com and we will investigate and respond within one month.
You also have the right to complain to a supervisory authority. In Malta that is the Office of the Information and Data Protection Commissioner (IDPC).
What we do not do
- We do not sell personal data, and we never will.
- We show no advertising in the app and run no advertising trackers in it.
- We do not build advertising profiles of children.
- We do not store the conversations children have with the tutor.
- We do not store photographs of schoolwork.
- We do not see, store or have any access to your card number.
- We do not make automated decisions producing legal or similarly significant effects. Adjusting a lesson’s difficulty is not such a decision.
Changes to this notice
The version before last said we had no accounts and no database. That was true when it was written, and it was replaced when optional saved progress shipped.
This version adds billing. We said in the previous version that billing was the next substantial change and that we would revise this notice before it shipped — this is that revision. It adds Stripe as a processor, says exactly what Stripe receives and what we store back, and adds the retention period for payment records.
This notice describes our actual practices accurately to the best of our knowledge. It has not yet been reviewed by a lawyer. If you spot something that looks wrong or unclear, please tell us at support@kiplrn.com.
See also our Safety & Privacy page, which says the same things in plainer language, and our Terms of Service.